Williams v. Fox

Background

Rodney Williams filed a petition under 28 U.S.C. § 2254, the federal law allowing a state prisoner to challenge custody based on a violation of federal law. He proceeded without a lawyer. A San Mateo County jury convicted Williams of second-degree murder, found that he personally used a deadly and dangerous weapon, and he received a sentence of 31 years to life. The California Court of Appeal affirmed the judgment, and the California Supreme Court denied review.

The trial evidence concerned Williams’s fatal stabbing of his coworker, Neil Lewis. Williams testified that Lewis approached him with a knife, that they struggled over it, and that Williams stabbed Lewis while trying to escape a chokehold. The prosecution presented eyewitness and medical evidence that, according to the opinion, contradicted Williams’s self-defense account. The jury received instructions on self-defense, imperfect self-defense, voluntary manslaughter, and the limits of self-defense, including an instruction stating that self-defense is unavailable when a person starts a fight intending to create an excuse to use force.

Claims and analysis

Williams raised eight claims. Claims 1 through 3 concerned the trial court’s failure to give California jury instruction CALCRIM No. 3471, which addresses self-defense when a defendant starts a fight or engages in mutual combat. Williams argued that the omission violated California law and federal due process, and that trial counsel was ineffective for failing to request the instruction.

The court held that Claim 1 was not cognizable, meaning it could not support federal habeas relief, because it relied only on California law. The court rejected Claim 2 because the instructions given allowed the jury to consider Williams’s self-defense theory, and any error from omitting CALCRIM No. 3471 did not have a substantial and harmful effect on the verdict. The court rejected Claim 3 because Williams failed to show that counsel’s failure to request the instruction prejudiced him. The court reasoned that the omitted instruction would have been duplicative and that Williams had not shown a reasonable probability of a different result.

Claim 4 challenged the failure to give a heat-of-passion voluntary-manslaughter instruction. The court held that, in a noncapital case, the claimed failure did not present a federal constitutional claim. It further held that the evidence and Williams’s own testimony supported self-defense rather than heat of passion, and that any error would have been harmless.

Claims 5 through 7 concerned statements Lewis made to friends, his girlfriend, and his brother before the killing. Williams argued that admitting the statements violated state evidence law and due process, violated the Sixth Amendment’s Confrontation Clause, and introduced improper bad-character evidence. The court held that state-law evidentiary errors generally do not warrant federal habeas relief unless they made the trial fundamentally unfair. It found permissible reasons for admitting the statements, including rebutting Williams’s self-defense theory and addressing his testimony. It also held that the statements were not testimonial because they were made during ordinary conversations with friends and family rather than to law enforcement. The court concluded that any error was harmless in light of the other evidence supporting the conviction. The court rejected Claim 7 separately because the relevant due-process rule concerning propensity evidence was not clearly established, and any error would not have substantially affected the verdict.

For Claim 8, Williams argued that the combined effect of the alleged errors deprived him of a fair trial. The court rejected this claim because it found no constitutional errors that could accumulate into a constitutional violation.

Disposition

Judge Edward Davila denied the petition for a writ of habeas corpus. The court also denied a certificate of appealability because Williams had not made the required substantial showing that a constitutional right was denied and had not shown that reasonable judges could debate the court’s assessment. The court entered judgment for Respondent Robert W. Fox, terminated pending motions, and closed the file. The opinion states that Williams could seek a certificate from the Court of Appeals under the applicable federal appellate rules.