Richard Walker Williams v. United States
(decided April 28, 2016).
Players: Associate Judges
Glickman and Thompson, Senior Judge Nebeker.
Opinion by Senior Judge Nebeker. Debra
Soltis for Mr. Williams. Robert E.
Morin, Trial Judge.
Facts: This case arises from a
fatal stabbing. Mr. Williams was appointed
standby counsel at trial after his two previous attorneys’ motions to withdraw were
granted. At the suppression hearing, Mr.
Williams alleged multiple instances of prosecutorial misconduct, including that
the government had knowingly allowed a witness to give false testimony at a
preliminary hearing and had altered police records. Mr. Williams’ standby counsel requested a
mental evaluation, and the staff psychologist at St. Elizabeth’s stated after a
screening interview that she could not discern whether Mr. Williams was “unwilling”
or “unable” to participate in court proceedings. Mr. Williams was then committed to St.
Elizabeths Hospital for a competency evaluation. At a competency hearing, a staff psychologist
at St. Elizabeths who had diagnosed Mr. Williams with malingering opined that
Mr. Williams was competent to represent himself without counsel. The psychologist’s opinion was based on her
daily interactions with Mr. Williams over the two-month evaluation period, as
well as her consultation and review of his records. Mr. Williams’ standby counsel also informed the
court that he believed Mr. Williams would be able to work with him on technical
legal questions. The court found Mr.
Williams competent, crediting the psychologist’s opinion that Mr. Williams
seemed able to turn his paranoia “off and on . . . like a light switch.” Mr. Williams then represented himself at
trial with his appointed attorney serving as standby counsel.
At trial, the government
introduced, without objection, stipulations as to Mr. Williams’ prior felony conviction (an element
of the charge of carrying a dangerous weapon having been previously convicted
of a felony (CDW)) and Mr. Williams’ release status at the time of the offense
(an element of the charge of committing an offense during release (OCDR)). Mr. Williams was convicted of second-degree
murder while armed, CDW, and two counts of OCDR.
Competency Issues: Whether the
court erred in finding Mr. Williams competent for self-representation and
whether the trial court abused its discretion by failing to re-examine sua sponte the issue of competency
during trial and sentencing.
Holding: No.
The DCCA found that the trial court’s determinations were supported by “ample
evidence,” including the court’s interactions with Mr. Williams throughout
pre-trial proceedings; evidence at the competency hearing; the court’s lengthy
formal inquiry with Mr. Williams on the issue of whether Mr. Williams was
competent to represent himself at trial; and Mr. Williams’ ability to file and
argue pro se motions and form defense theories.
And according to the DCCA, the trial court did not err by failing to
re-examine the issue sua sponte,
given that during trial, Mr. Williams was able to cross-examine witnesses
effectively, highlight inconsistencies and gaps in the government’s evidence,
and present his own version of the incident.
Other Crimes Issue: Whether the
trial court committed plain error by allowing the government to introduce
evidentiary stipulations at trial regarding Mr. Williams’ felony conviction and
release status.
Holding: Yes. The
DCCA found that (1) OCDR does not create a separate offense, but is a sentencing
enhancement, and (2) evidence of a prior felony conviction is unnecessary and
prejudicial if the defendant is
willing to stipulate to this fact. Slip
Op. at 22-24 (citing Eady v. United
States, 44 A.3d 257 (D.C. 2012)).
Therefore, it was plain error for the trial court to admit evidence of the
appellant’s release status and prior conviction, in light of Mr. Williams’
stipulations on these issues. However,
this error did not warrant reversal, given that two “credible” eyewitnesses and
video evidence supported the government’s case and that the prejudicial effect of
the stipulations was limited by the trial court’s limiting instructions. NG
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