Williams v. State


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Docket Number: 2011-KA-00081-COA
Linked Case(s): 2011-KA-00081-COA ; 2011-CT-00081-SCT ; 2011-CT-00081-SCT ; 2011-CT-00081-SCT

Supreme Court: Opinion Link
Opinion Date: 03-28-2013

Court of Appeals: Opinion Link
Opinion Date: 03-27-2012
Opinion Author: Griffis, P.J.
Holding: Affirmed

Additional Case Information: Topic: Sexual battery - Voluntariness of confession - Competent to waive rights
Judge(s) Concurring: Lee, C.J., Irving, P.J., Barnes, Ishee, Roberts, Carlton, Maxwell and Fair, JJ.
Dissenting Author : Russell, J.
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 this judgment on 3/28/2013. The SCT opinion can be found at http://courts.ms.gov/Images/Opinions/CO84033.pdf

  Party Name: Attorney Name:  
Appellant: Tyrell Williams




LESLIE S. LEE HUNTER NOLAN AIKENS



 

Appellee: State of Mississippi OFFICE OF THE ATTORNEY GENERAL: LADONNA C. HOLLAND  

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Topic: Sexual battery - Voluntariness of confession - Competent to waive rights

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 the trial court erred in finding that Williams knowingly, intelligently, and voluntarily waived his Miranda rights and made the incriminating statements. The State meets its burden and establishes its prima facie case of the voluntariness of a confession by presenting the testimony of a witness with personal knowledge—which will usually be a police officer who was present when the confession was made—that the confession was voluntarily given, without any coercion, threats, or offers of reward. Here, the State presented testimony from Officer Joel who was present during the confession. Officer Joel testified he read Williams his Miranda rights, and Williams signed a waiver of those rights. Officer Joel stated that Williams appeared to understand his rights at the time he was questioned. Officer Joel testified Williams was responsive to his questions, and Williams even offered a defense to the crime. Williams freely offered that he believed the victim to be eighteen years old. Williams relies on the evidence that he has a Full Scale IQ of 53. Williams also points to the statements from the Mississippi State Hospital doctors indicating they could not form an opinion to whether he was competent to waive his constitutional rights with Officer Joel. However, the doctors unanimously found Williams was able to waive his constitutional rights and to stand trial. Thus, the evidence supports the circuit judge’s finding that the confession was voluntary.


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