Michael Jerome Williamsv.The State
A jury convicted Michael Williams of family-violence aggravated assault and possessing a knife during the commission of a felony after evidence that he confronted a teenage family member with a knife during an argument in the child’s home. Williams challenged the sufficiency of the evidence, a jury instruction, the handling of a child witness, and trial counsel’s performance. The Georgia Court of Appeals held that the evidence was sufficient despite the absence of blood on the knives recovered at the scene. The victim and the victim’s mother described the stabbing, the victim’s injuries and blood loss were consistent with that account, and the jury was responsible for resolving conflicts in the testimony. The court nevertheless vacated the convictions and remanded for an evidentiary hearing on ineffective assistance. The existing record could not resolve whether trial counsel’s alleged errors were prejudicial. If the trial court finds counsel ineffective, Williams is entitled to a new trial; if not, the court may reenter the convictions, subject to a new appeal.
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