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Williams v. State

CRIMINAL LAW

Peter Graham

In Williams v. State, 486 P.3d 1134 (Alaska Ct. App. 2021), the Court of Appeals affirmed a conviction of second-degree sexual assault. (Id. at 1135). Williams was convicted of second-degree sexual assault following a jury trial in the Superior Court, First Judicial District, Juneau. (Id.). Williams raised four issues on appeal. (Id.). First, Williams argued that the trial court improperly admitted text messages sent from his phone to the victim. (Id.) Because Williams’s attorney had not raised this argument at trial, it was not preserved and thus the court required a finding of plain error. (Id.) Because Williams’s attorney had acknowledged the text messages were sent from Williams’s phone, the court found no plain error and rejected this argument. (Id. at 1136). Williams further argued that even if the texts were sent from his phone, there was insufficient evidence to show that he was the author. (Id.). The court determined that the State presented sufficient evidence to the contrary and rejected this argument. (Id.). Second, Williams argued that the trial court erred in denying his motion for a mistrial based on the victim’s demeanor on the witness stand. (Id.). In prior decisions, the court had previously acknowledged the risk that a witness’s demeanor will lead the jury to decide the case based primarily on emotion or sympathy for the witness. (Id. at 1137). Nevertheless, the court did not find the abuse of discretion required to overturn the trial court’s decision and rejected Williams’s argument. (Id.). Third, Williams argued that the evidence was insufficient to support his conviction. (Id. at 1138). When reviewing a claim of insufficient evidence, the court must view the evidence and all reasonable inferences in the light most favorable to upholding the jury’s verdict. (Id.). The court rejected Williams’s argument, finding that the State presented sufficient evidence to show that the victim was incapacitated and that Williams knew this at the time of the assault. (Id.). Lastly, Williams argued that his sentence of 35 years with 12 years suspended was excessive given that the trial court failed to conduct an on-the-record review of sentences imposed in similar cases. (Id.). The court rejected this argument, stating that the trial court’s thorough application of Chaney criteria provided sufficient detail to communicate the basis for its sentencing decision. (Id.). The Court of Appeals thereby affirmed the judgment of the trial court and upheld Williams’s conviction of second-degree sexual assault over Williams’s four issues on appeal. (Id. at 1135).

Williams v. State

CRIMINAL LAW

Peter Graham

In Williams v. State, 486 P.3d 1134 (Alaska Ct. App. 2021), the Court of Appeals affirmed a conviction of second-degree sexual assault. (Id. at 1135). Williams was convicted of second-degree sexual assault following a jury trial in the Superior Court, First Judicial District, Juneau. (Id.). Williams raised four issues on appeal. (Id.). First, Williams argued that the trial court improperly admitted text messages sent from his phone to the victim. (Id.) Because Williams’s attorney had not raised this argument at trial, it was not preserved and thus the court required a finding of plain error. (Id.) Because Williams’s attorney had acknowledged the text messages were sent from Williams’s phone, the court found no plain error and rejected this argument. (Id. at 1136). Williams further argued that even if the texts were sent from his phone, there was insufficient evidence to show that he was the author. (Id.). The court determined that the State presented sufficient evidence to the contrary and rejected this argument. (Id.). Second, Williams argued that the trial court erred in denying his motion for a mistrial based on the victim’s demeanor on the witness stand. (Id.). In prior decisions, the court had previously acknowledged the risk that a witness’s demeanor will lead the jury to decide the case based primarily on emotion or sympathy for the witness. (Id. at 1137). Nevertheless, the court did not find the abuse of discretion required to overturn the trial court’s decision and rejected Williams’s argument. (Id.). Third, Williams argued that the evidence was insufficient to support his conviction. (Id. at 1138). When reviewing a claim of insufficient evidence, the court must view the evidence and all reasonable inferences in the light most favorable to upholding the jury’s verdict. (Id.). The court rejected Williams’s argument, finding that the State presented sufficient evidence to show that the victim was incapacitated and that Williams knew this at the time of the assault. (Id.). Lastly, Williams argued that his sentence of 35 years with 12 years suspended was excessive given that the trial court failed to conduct an on-the-record review of sentences imposed in similar cases. (Id.). The court rejected this argument, stating that the trial court’s thorough application of Chaney criteria provided sufficient detail to communicate the basis for its sentencing decision. (Id.). The Court of Appeals thereby affirmed the judgment of the trial court and upheld Williams’s conviction of second-degree sexual assault over Williams’s four issues on appeal. (Id. at 1135).