Joel Williams v. State of Arkansas

2025 Ark. App. 194
CourtCourt of Appeals of Arkansas
DecidedApril 2, 2025
StatusPublished
Cited by1 cases

This text of 2025 Ark. App. 194 (Joel Williams v. State of Arkansas) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joel Williams v. State of Arkansas, 2025 Ark. App. 194 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 194 ARKANSAS COURT OF APPEALS DIVISION IV No. CR-24-413

Opinion Delivered April 2, 2025

JOEL WILLIAMS APPEAL FROM THE MISSISSIPPI APPELLANT COUNTY CIRCUIT COURT, CHICKASAWBA DISTRICT V. [NO. 47BCR-21-138]

STATE OF ARKANSAS HONORABLE SCOTT A. ELLINGTON, APPELLEE JUDGE

AFFIRMED

CASEY R. TUCKER, Judge

At the conclusion of a three-day jury trial, Joel Williams was convicted as a habitual

offender of first-degree murder and committing a terroristic act in concert with two or more

other people, and he received a five-year enhancement for using a firearm in the commission

of these crimes. Following the jury’s recommendation, the Mississippi County Circuit Court

sentenced him to twenty years’ imprisonment for the murder conviction and fifteen years’

imprisonment for the terroristic-act conviction. With the five-year firearm enhancement and

the consecutive sentences, Williams received a total of forty years’ incarceration in the

Arkansas Division of Correction.1 He raises five points on appeal, asserting that the circuit

1 The State notes that the sentencing order contains a scrivener’s error. The original order does have an error; however, the court entered an amended order that corrects that error. court erred in denying his motion for directed verdict, denying his Batson challenge, denying

his motion for a mistrial, refusing to instruct the jury with AMI Crim. 2d 603, and requiring

Williams and his codefendants to wear ankle monitors at trial. We affirm.

When reviewing a challenge to the sufficiency of the evidence to support a conviction,

this court views the evidence in the light most favorable to the State and considers only that

evidence that supports the verdict. Brooks v. State, 2024 Ark. App. 241, 687 S.W.3d 397.

Applying the proper perspective to our review of the case before us, the following events

unfolded on the afternoon of April 7, 2021, in Blytheville, Arkansas. 2 Shortly after 4:00

p.m., Williams and codefendants Tyree Johnson and Willvontae Westmorland, together in

one car, drove down Walls Street, turned left on Myrtle Street, and parked between two

houses that faced Walls Street. They backed into their parking spot between two houses.

None of the three lived in either of the houses between which they parked. The three men

exited the vehicle, leaving the doors open; retrieved various firearms, including an assault

rifle; and milled around in the area of the car.

Approximately three minutes later, a black BMW driven by Jamion Sims came down

Walls Street. When it was in front of the house behind which Williams and his cohorts had

parked, the BMW slowed, and four armed men began rolling and jumping out of the car.

Williams, Johnson, and Westmorland ran toward the men who had exited the BMW. A

gunfight ensued as the BMW continued slowly down the street. The men from both sides

2 In addition to testimony, the evidence included surveillance video from multiple security cameras in various locations.

2 were running, dodging, and ducking as they fired. The men from the BMW ran toward it

and began getting back inside the car as it slowly drove away from the scene. As they did so,

the men in Williams’s group continued firing.

Everything came to a halt when Lieutenant Michael Dannar of the Blytheville Police

Department, rammed his police cruiser into the BMW. After he detained three of the

shooters from the BMW, one of the men informed him that the driver had been shot.

Lieutenant Danner found the driver slumped over the steering wheel with a gunshot wound

to his head. Even though the shootout had lasted less than one minute, the police recovered

seventy-three shell casings from the scene.

The BMW’s driver, Sims, was the only fatality from the gunfight that took place that

day. Mr. Sims had never exited the car; however, there was a handgun on the floorboard by

his feet. He died from a single gunshot wound to his head. It entered from the left, behind

his ear, and exited to the right, with a slightly front-to-back trajectory. The medical examiner

testified that the shot was fired from a distance greater than three feet. The direction the car

was traveling placed Williams and his associates on the driver’s side of the BMW during the

exchange. There were concentrated groups of shell casings: forty-four of the seventy-three

casings were found in the area where Williams, Johnson, and Westmorland had been during

the shootout. Williams and his associates fled the scene when law enforcement arrived.

Officers identified them from the multiple surveillance videos in the area, and they were

arrested.

3 Williams, Johnson, and Westmorland were tried together in a jury trial in January

2024.3 The jury found Williams and his codefendants guilty of first-degree murder,

committing a terroristic act, and using a firearm in the commission of these crimes. The

court sentenced Williams to a total of forty years’ imprisonment in accordance with the jury’s

recommendation, and Williams timely appealed.

I. Sufficiency of the Evidence

Williams argues on appeal that his convictions are not supported by sufficient

evidence because (1) the State did not prove who fired the fatal shot, and (2) the State failed

to negate his justification defense. We disagree.

When reviewing a challenge to the sufficiency of the evidence, we consider only that

evidence that is favorable to the State and supports the verdict. Brooks v. State, 2024 Ark.

App. 241, at 4, 687 S.W.3d 397, 400. We will affirm if substantial evidence supports the

judgment of conviction. Id. Substantial evidence is evidence that is of sufficient force and

character that it will, with reasonable certainty, compel a conclusion without resorting to

speculation or conjecture. Id. We defer to the jury on matters of witness credibility. Id.

Jurors may consider the evidence as a whole rather than view each fact in isolation. Id.

3 Johnson and Westmorland appeal their convictions in separate appeals also handed down today. See Johnson v. State, 2025 Ark. App. 198, ___ S.W.3d ___; Westmorland v. State, 2025 Ark. App. 196, ___ S.W.3d ___.

4 A. Causation

Willams asserts that pursuant to Anderson v. State, 2011 Ark. 461, 385 S.W.3d 218,

the State was required to prove that but for Williams’s actions, Sims would not have died.

Thus, his argument goes, since the State cannot prove which bullet pierced Sims’s skull and

from which firearm that bullet was fired, there is insufficient evidence to support Williams’s

murder conviction. We are not persuaded by Anderson, supra, as it is not an accomplice-

liability case. Williams’s analysis ignores the law of accomplice liability.

Williams was convicted of felony murder, which requires the State to prove the

following:

(1) Acting alone or with one (1) or more other persons:

(A) The person commits or attempts to commit a felony; and

(B) In the course of and in the furtherance of the felony or in immediate flight from the felony, the person or an accomplice causes the death of any person under circumstances manifesting extreme indifference to the value of human life[.]

Ark. Code Ann. § 5-10-102(a) (Repl. 2024). The underlying felony for Williams’s murder

conviction was committing a terroristic act, which a person commits if, “while not in the

commission of a lawful act, the person . . . [s]hoots at or in any manner projects an object at

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Related

Joel Williams v. State of Arkansas
2025 Ark. App. 194 (Court of Appeals of Arkansas, 2025)

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2025 Ark. App. 194, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joel-williams-v-state-of-arkansas-arkctapp-2025.