Law School Case Brief
Williamson v. State - 1991 OK CR 63, 812 P.2d 384
The admissibility of photographs is a matter within the trial court's discretion. Absent an abuse of that discretion, an appellate court will not reverse the trial court's ruling. For photographs to be admissible, their content must be relevant and their probative value must substantially outweigh their prejudicial effect. The fact that the pictures are gruesome does not of itself cause the photographs to be inadmissible.
More than four years after the victim was found dead, defendant Ronald Keith Williamson was charged with her murder. After a jury trial, Williamson was convicted and sentenced to death. Williamson sought review of the judgment. Williamson alleged error in the admission of photographic evidence. Specifically, he argued that the photographs were not relevant, as there was no dispute concerning the cause of death and that he was prejudiced by the repetitive nature of the photographs.
In a criminal trial, did the trial court abuse its discretion in admitting several pieces of photographic evidence?
In affirming, the Court of Criminal Appeals of Oklahoma held (1) that the pre-accusation delay in filing the murder charge against defendant Williamson did not deny him due process of law in violation of U.S. Const. Amend. V because there was good cause for the delay and he failed to establish prejudice by the delay; (2) that substantial independent evidence was presented that directly established both the corpus delicti and the truthfulness of Williamson's admissions and confessions; (3) that the trial court did not abuse its discretion in admitting several pieces of photographic evidence because Williamson failed to demonstrate that he was prejudiced by the slight repetition of photographs; (4) that the evidence of Williamson's prior unadjudicated acts of violence along with the callous nature in which he killed the victim supported the jury's finding of the continuing threat aggravating circumstance in recommending the sentence of death; and (5) that Williamson failed to show that his sentence was rendered unreliable by a breakdown in the adversary process caused by ineffective assistance of counsel. The Court addressed various assignments of errors, including the ineffective assistance of counsel claim. Under U.S. Const. Amend. VI and XIV, and Okla. Const. art. II, § 20, an accused has a fundamental right to the reasonably effective assistance of counsel. The Court looked to the Strickland v. Washington (1984) two-part test, and the defendant must overcome the presumption that counsel's conduce might be considered sound trial strategy.
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