Williams v. State
| Docket Number: | 2011-CT-00081-SCT Linked Case(s): 2011-KA-00081-COA ; 2011-KA-00081-COA ; 2011-CT-00081-SCT ; 2011-CT-00081-SCT |
|
| Supreme Court: | Opinion Link Opinion Date: 03-28-2013 Opinion Author: Coleman, J. Holding: Reversed and Remanded |
|
| Court of Appeals: |
Opinion Link Opinion Date: 03-27-2012 |
|
| Additional Case Information: |
Topic: Sexual battery - Suppression of statement - Waiver of rights - Mental retardation - State's burden Judge(s) Concurring: Waller, C.J., Dickinson and Randolph, P.JJ., Lamar and Pierce, JJ. Concur in Part, Dissent in Part 1: Chandler, J. Concur in Part, Dissent in Part Joined By 1: Kitchens and King, JJ. Procedural History: Jury Trial Nature of the Case: CRIMINAL - FELONY |
|
| Trial Court: |
Date of Trial Judgment: 12-07-2010 Appealed from: Bolivar County Circuit Court Judge: Charles E. Webster Disposition: CONVICTED OF SEXUAL BATTERY AND SENTENCED TO TWENTY YEARS IN THE CUSTODY OF THE MISSISSIPPI DEPARTMENT OF CORRECTIONS District Attorney: Brenda Fay Mitchell Case Number: 2009-079-CR2 |
|
| Note: | The Supreme Court reversed and remanded after finding that the trial judge applied an incorrect legal standard at the suppression hearing. The original Court of Appeals opinion can be found at http://courts.ms.gov/Images/Opinions/CO74570.pdf . | |
| Party Name: | Attorney Name: | |||
| Appellant: | Tyrell Williams |
OFFICE OF INDIGENT APPEALS: HUNTER NOLAN AIKENS |
||
| Appellee: | State of Mississippi | OFFICE OF THE ATTORNEY GENERAL: LADONNA C. HOLLAND |
|
|
Synopsis provided by:  If you are interested in subscribing to the weekly synopses of all Mississippi Supreme Court and Court of Appeals hand downs please contact Tammy Upton in the MLI Press office. |
|
| Topic: | Sexual battery - Suppression of statement - Waiver of rights - Mental retardation - State's burden |
| Summary of the Facts: | Tyrell Williams was convicted of sexual battery and sentenced to twenty years. He appeals. |
| Summary of Opinion Analysis: | Williams argues that he did not knowingly waive his constitutional rights, and the trial court therefore erred in denying his motion to suppress his inculpatory statement. When the admissibility of a confession is challenged, the State has the burden of proving voluntariness of the confession beyond a reasonable doubt. Waiver of one’s rights in making that confession must be knowing and intelligent. Where the issue of mental retardation is raised, as it is in this case, the trial judge must first determine whether the accused, prior to the confession, understood the content and substance of the Miranda warning and the nature of the charges of which he was accused. At the end of the suppression hearing, the trial judge concluded: “I cannot rule that [Williams] did not understand his rights as they were stated to him by Jeff Joel. Therefore, I’m not going to suppress the statement.” In so finding, the trial judge reversed the applicable standard and improperly placed the burden on the defendant to prove that he did not understand his rights. The burden was on the State to prove beyond a reasonable doubt that Williams did understand his rights and that he made a knowing, intelligent, and voluntary confession. Thus, the case is reversed and remanded for a new trial. |
Home | Terms of Use | About the JDP | Feedback | Using JDP | MC Law Library | Mississippi Supreme Court
