Williams v. State
| Decision Date | 08 March 2022 |
| Docket Number | S22A0170 |
| Court | Georgia Supreme Court |
| Parties | WILLIAMS v. THE STATE. |
Allen Williams appeals his conviction for felony murder in connection with the death of his girlfriend, Betty Ranow.[1] Williams argues on appeal that the trial court erred in admitting evidence concerning his alleged beating of another person and in failing to conduct an evidentiary hearing to determine whether his statements to the police in connection with that incident were freely and voluntarily given before they were introduced at trial. Because we conclude that any error in the admission of this evidence was harmless, we affirm.
The evidence presented at trial showed that in 2010, Williams and Ranow lived together in a house in Lawrenceville. At around 8:15 p.m. on December 18, Ranow approached a woman who was sitting in her car outside a doughnut shop near the house where Ranow and Williams lived. The woman, who did not know Ranow, described her as appearing "frazzled," intoxicated, and inappropriately dressed for the cold December weather, as she was wearing only jeans, a t-shirt and slippers. Ranow asked the woman for a ride to downtown Lawrenceville, and the woman, who had just come from church and who said she felt sorry for Ranow, agreed to Ranow's request. They prayed together on the drive, and when they reached their destination, the woman removed her own yellow coat and gave it to Ranow to wear. The coat was clean with no stains on it at that time.
At around 8:53 that night, Officer Brad Daugherty of the Lawrenceville Police Department ("LPD") responded to a call for a welfare check on Ranow outside a restaurant in downtown Lawrenceville. Ranow, with whom Officer Daugherty was familiar, asked him to drive her home. Ranow was wearing a clean "mustard yellow" coat with no stains, and Officer Daugherty could smell alcohol on her person. Officer Daugherty drove Ranow to the house she shared with Williams. He dropped her off in front of the house but did not see her go inside.
The next morning, at around 5:48 a.m., Williams called 911 from their house to ask for an ambulance. Brent Moss, an LPD patrol officer, was the first to arrive at the scene. Williams led Officer Moss inside the house where Ranow's body was lying on the floor. Williams placed his hand on Ranow's chest and told Officer Moss that Ranow was "barely breathing." However, Officer Moss could see that Ranow was not breathing at all, and he directed Williams outside. Officer Moss smelled alcohol coming from Williams and testified that Williams appeared intoxicated. Williams told Officer Moss that when Ranow arrived home, [2] she had already been beaten. According to Williams, Ranow told him she had been drugged and assaulted and that the people who did that put her clothes in the trash can outside. Williams also told police that Ranow came home wearing a yellow coat that Williams had never seen before and that the coat was outside in a trash can. He told one officer exactly where to find that trash can. Williams further asserted that whoever gave Ranow the yellow coat also gave her the drugs and beat her up.
Emergency medical personnel arrived at the house approximately three minutes after Officer Moss. One of the paramedics who responded to the scene testified that Ranow was deceased when he arrived. Her body was cold to the touch and showed signs of lividity where the blood had settled. There was a pool of dried blood around Ranow's head and dried blood around her eyes.
Officer Moss kept Williams from going back inside the house, and Williams became irate, leading the officer to call for backup. An LPD watch commander, who arrived at the crime scene in response to Officer Moss's call, observed that Williams had blood on his head and that his right hand was "scuffed up." The watch commander said that Williams appeared very nervous and fidgety and was trying to leave the scene, saying he had "other places to go." The watch commander ordered that Williams be secured in the back of a patrol car and that a security sweep of the house be conducted. No one else was located inside.
Police observed blood inside the house around Ranow's body, blood smears on the front doorframe, and blood inside the front screened-in porch; only a few drops of blood were discovered outside the enclosed porch on the walkway leading to the porch door. There was no blood trail leading from the street and no blood in the yard, on the driveway, or on the street itself. The officers also recovered a yellow jacket with what appeared to be blood stains from an open trash container outside the house. At trial, the woman who gave Ranow a ride to downtown Lawrenceville identified it as the jacket she had given Ranow, and Officer Daugherty confirmed that the jacket appeared to be the one Ranow was wearing when he dropped her off at the house. Later, after Williams was transported to the police station, officers observed that Williams's right hand was swollen, with discoloration to the back of his hand, scuff marks, and abrasions. He was taken to the hospital for treatment.
The medical examiner who conducted the autopsy found severe bruising, abrasions, and swelling on Ranow's body and tread marks on her face consistent with footwear. She also observed that Ranow had a "raccoon-eye appearance," caused by the entrapment of blood in the soft tissues of the eyes, which, the medical examiner explained, is indicative of head trauma. The medical examiner discovered injuries to other parts of Ranow's body as well and observed that Ranow had internal injuries corresponding to her external injuries, including eight broken ribs. She testified that all the injuries were indicative of blunt force trauma, and the injuries to Ranow's head resulted in brain damage and diffuse bleeding within the scalp, factors that can lead to immediate loss of consciousness, concussion, and death. Based on the post-mortem examination, the medical examiner concluded that Ranow's manner of death was homicide caused by blunt force trauma to her head, neck, and chest. The medical examiner also observed that Ranow's body was dressed in clean clothes, indicating that they were not on her body at the time her injuries occurred and that the placement of the clothing on the body suggested that someone else had dressed her because one of Ranow's arms was not fully in the sleeve of her sweater and her pants were not pulled over her hips. DNA recovered from Ranow's body was tested and determined to match Williams's DNA.
At trial, the State presented evidence of Williams's involvement in two previous physical altercations: a June 2010 incident involving Ranow and an August 2010 incident involving Ronald Strode, who lived in the Lawrenceville house with Ranow and Williams at the time.[3] With regard to the June 2010 incident, a retired LPD police officer testified that while he was still employed with the LPD, he came upon an altercation between Williams and Ranow at a gas station within walking distance of their house. During the altercation, the officer saw Williams hit Ranow in the chest a few times, almost causing her to fall down. The officer placed both Williams and Ranow under arrest for public drunkenness.
The State presented two witnesses to testify about the incident involving Strode, which occurred on the night of August 12 to 13, 2010. Strode testified that sometime during the night, Williams came into Strode's bedroom, asked Strode if he had seen Ranow, and used his fists to beat Strode in the face, head, and chest. Strode was able to break away from Williams and walk to the nearby house of a friend, who called an ambulance. Strode was taken to the hospital for treatment, which included brain surgery. The State also presented testimony from a uniform patrol sergeant from the Gwinnett County Police Department who investigated the Strode incident. He testified that he interviewed Williams after Strode identified Williams as his assailant. The sergeant testified that during the custodial interview, Williams said he returned home on the night of August 12 to 13, and, while still outside, saw Ranow and Strode through the window. Williams told the sergeant that Strode and Ranow were on the bed together, with Strode's hand between Ranow's legs. Williams said he went inside and confronted Strode about the condition of the house, which was in disarray, and Ranow told Williams that Strode had attempted to rape her. Williams admitted to the sergeant that, at some point during the night, he struck Strode once with an open hand, because Williams believed that he had interrupted an attempted rape. Williams explained that he was upset because Ranow did not appear to be resisting Strode and that she had been unfaithful to Williams many times in the past.
1. Williams asserts that the trial court erred in admitting evidence of the Strode incident pursuant to OCGA § 24-4-404 (b) ("Rule 404 (b)")[4] for the purpose of showing identity.
In order to introduce extrinsic evidence under Rule 404 (b), the State must show:
(1) that the evidence is relevant to an issue in the case other than the defendant's character; (2) that the probative value of the evidence is not substantially outweighed by its undue prejudice; and (3) that there is sufficient proof for a jury to find by a preponderance of the evidence that the defendant committed the other act.
Strong v. State, 309 Ga. 295, 300 (2) (a) (845 S.E.2d 653) (2020). And "[w]hen evidence is offered pursuant to Rule 404 (b) to prove identity, it must satisfy a particularly stringent analysis." Moon v. State, 312 Ga. 31, 53 (3) (c) (iii) (860 S.E.2d 519) (2021) (citation and punctuation omitted).
The extrinsic act must be a "signature" crime, and the defendant must have...
To continue reading
Request your trial