Humphrey v. Williams

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In August 2004, Jimmie Ray Williams filed a pro se petition for habeas corpus alleging, among other claims, that Billy Grantham, his attorney at trial and on direct appeal, provided ineffective assistance of counsel. In 2002, a jury Williams of sexually molesting his 13-year-old stepdaughter and her 14-year-old friend in 2000, after a trial at which his 20-year-old daughter was allowed to testify, as a similar transaction, that Williams touched her sexually four times in one night in 1993, when she was 11 years old and living with him in Florida. The trial court sentenced Williams to serve a total of 20 years in prison followed by 20 years on probation, and the Court of Appeals affirmed. Williams claimed that Grantham conducted a deficient pretrial investigation by failing to obtain Florida court records showing that the alleged similar transaction never took place. Williams argued that if Grantham had conducted a competent investigation and found those records, his daughter’s testimony would have been excluded before trial or successfully impeached at trial, creating a reasonable probability that the trial verdict would have been more favorable to Williams. The habeas court initially denied Williams' petition in November 2006, but in January 2008 the Supreme Court granted his application to appeal and vacated that judgment because the habeas court had not allowed Williams a full and fair opportunity to present his claims. On remand, at a new evidentiary hearing, Williams presented the Florida court records and showed that they were readily available to Grantham at the time of trial. The habeas court entered a detailed order setting aside Williams' convictions. The Warden appealed, arguing, among other things, that reversal was required because the Florida court records on which the habeas court based its finding of ineffective assistance of counsel were never admitted into evidence in the habeas proceedings; the court erred in finding deficient performance; the court erred in finding prejudice based on its erroneous determination that the Florida records amounted to acquittal evidence that collaterally estopped the admission of the similar transaction; and the court erred in finding prejudice because of the "overwhelming evidence" of Williams' guilt, aside from the similar transaction testimony, that was presented at trial. The Supreme Court found that the Florida court records were indeed admitted into evidence at the 2008 habeas hearing, and Court agreed with the habeas court that Grantham's investigation of the alleged similar transaction was professionally deficient. The Warden was correct that the habeas court erred in treating the Florida records as acquittal evidence precluding the admission of the similar transaction testimony, but the Warden was wrong in his assertion that the evidence at Williams' trial, aside from the similar transaction evidence, was overwhelming. The Supreme Court affirmed the habeas court's judgment. View "Humphrey v. Williams" on Justia Law