State v. Williams

CourtCourt of Appeals of Arizona
DecidedFebruary 6, 2026
Docket1 CA-CR 25-0285 PRPC
StatusUnpublished

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

Bluebook
State v. Williams, (Ark. Ct. App. 2026).

Opinion

NOTICE: NOT FOR OFFICIAL PUBLICATION. UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.

IN THE ARIZONA COURT OF APPEALS DIVISION ONE

STATE OF ARIZONA, Respondent,

v.

KRISTI MEGAN WILLIAMS, Petitioner.

No. 1 CA-CR 25-0285 PRPC FILED 02-06-2026

Petition for Review from the Superior Court in Mohave County No. S8015CR202101029 The Honorable Douglas Camacho, Judge Pro Tempore

REVIEW GRANTED; RELIEF DENIED

COUNSEL

Mohave County Attorney’s Office, Kingman By Leah Nelson Counsel for Respondent

Janelle A. Mc Eachern Attorney at Law, Chandler By Janelle A. Mc Eachern Counsel for Petitioner STATE v. WILLIAMS Decision of the Court

MEMORANDUM DECISION

Presiding Judge David B. Gass, Judge Anni Hill Foster, and Chief Judge Randall M. Howe delivered the decision of the Court.

PER CURIAM:

¶1 Petitioner Kristi Megan Williams seeks review of the superior court’s order denying her petition for post-conviction relief under Rule 32, Arizona Rules of Criminal Procedure. This matter is petitioner’s first petition.

¶2 In her petition, Williams raised several issues, including arguing the superior court should have excluded her statements to police officers for 2 reasons: (1) because they were involuntary and (2) because she made them after she invoked her rights under State v. Miranda, 384 U.S. 436 (1966). The superior court summarily denied her requested relief on the voluntariness argument, but ordered an evidentiary hearing on the Miranda issue. Even so, during the evidentiary hearing Williams offered evidence about the voluntariness issue, which the superior court addressed in its post-hearing ruling.

¶3 In her petition before the court, Williams challenges the superior court’s voluntariness ruling, but she relies on the evidence produced in the Miranda hearing. Based on Williams’s petition and the record, the court grants review, but denies relief.

FACTUAL AND PROCEDURAL HISTORY

¶4 The facts underlying Williams’s convictions are convoluted and unusual. As discussed below, the court previously granted Williams some relief in her direct appeal in State v. Williams, 1 CA-CR 22-0388, 2023 WL 5371366, at *1 (App. Aug. 22, 2023) (mem. decision). That case lays out the factual background underlying her convictions, and the court will not repeat the facts unless necessary to understand the issues here.

I. Late one night, Williams found herself at a suicide scene on the side of the road in a remote area in Lake Havasu.

¶5 The court views the facts and all reasonable inferences in the light most favorable to affirming the superior court’s ruling. See State v.

2 STATE v. WILLIAMS Decision of the Court

Reed, 252 Ariz. 236, 237 n.2 (App. 2021) (applying principle to appellate review of post-conviction relief proceedings).

¶6 Williams was driving a Dodge Challenger in a remote area in Lake Havasu when she picked up a hitchhiker who was on crutches. At one point, she pulled to the side of the road so they could smoke marijuana. After smoking, Williams noticed the Challenger was stuck, leaving them stranded. After a while, she went looking for help and came across a suicide scene. The hitchhiker came along later, at which point Williams showed him the truck and then the body.

¶7 Rather than going to the police, Williams took the deceased’s truck and trailer (including the tools in the trailer) and drove to a friend’s house, where she stayed for several hours before her friend drove her back to the scene. Williams and her friend left the deceased’s truck and trailer (including the tools) parked near the friend’s house. The hitchhiker did not leave the scene with Williams and later called the police.

¶8 Williams talked to several officers near the scene. During the conversations, her story evolved because she wanted to make sure the police would not tie her to the methamphetamine pipe in the Challenger she was driving earlier. She eventually admitted to taking the deceased’s truck and trailer after finding his body. The police also determined someone reported the Challenger Williams had been driving as stolen.

¶9 A grand jury indicted Williams on 2 counts of theft of a means of transportation, class 3 felonies (counts 1 & 2), 1 count of theft (value over $4000), a class 3 felony (count 3), and 1 count of false reporting to a law enforcement agency, a class 1 misdemeanor (count 4). After trial, a jury convicted Williams of 1 count of theft of means of transportation and 1 count of theft of property (the tools) with a value between $1,000 and $2,000. The superior court found her guilty of 1 count of misdemeanor false reporting to a law enforcement agency. Williams’s criminal history resulted in the court classifying her as a category 3 offender. The superior court thus sentenced her to 18 years in prison for the theft of means count, a concurrent sentence of 4 years in prison for the theft of property (the tools) count, and time served for the misdemeanor false reporting to a law enforcement agency.

¶10 On appeal, the State conceded the superior court should have merged the convictions for theft of means and for theft of property (the tools). The superior court merged the 2 convictions, affirmed the sentence for theft of means, but vacated the sentence for theft of property.

3 STATE v. WILLIAMS Decision of the Court

¶11 Williams then began this post-conviction relief process.

II. Williams raised 4 issues in her petition for post-conviction relief before the superior court, only 1 of which she pursues here.

¶12 Williams sought relief on these grounds:

1. The addendum to the indictment contained errors.

2. The superior court violated her confrontation clause rights because the State never called the hitchhiker as a witness, but the police still testified about some of his statements to them.

3. Her confessions were involuntary because the police coerced her into admitting she drove the deceased’s truck and trailer.

4. Her confessions were involuntary because she made them after she invoked her Miranda rights.

¶13 After a response and reply, the superior court denied Williams’s petition on the first 3 issues. The superior court found it could not resolve the fourth, the Miranda issue, based on the evidence presented at trial so it ordered an evidentiary hearing on the Miranda issue.

¶14 In its ruling, the superior court noted Williams seemed to suggest the State engaged in prosecutorial misconduct and her trial counsel’s performance was ineffective because trial counsel did not pursue the claims sooner. But the superior court ruled the record did not support those claims. Williams’s petition before this court does not mention prosecutorial misconduct or ineffective assistance of counsel.

III. After an evidentiary hearing, the superior court denied Williams’s requested relief.

¶15 The superior court held a 2-hour evidentiary hearing on whether the police continued questioning her after she invoked her Miranda rights. Williams and 2 of the investigating officers testified.

¶16 Williams said she believed the police gave her Miranda rights twice, and she said she invoked her right to remain silent at least once. She said several things affected her mental state that night which resulted in her unclear memory of the events. First, she was scared that night. Second, at her friend’s house, she consumed ½ a bottle of vodka and smoked both marijuana and methamphetamine. She also said she was hallucinating when she spoke to the police. Still, in the police body camera footage, she

4 STATE v. WILLIAMS Decision of the Court

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
State of Arizona v. Phil Gutierrez
278 P.3d 1276 (Arizona Supreme Court, 2012)
State v. Cuffle
828 P.2d 773 (Arizona Supreme Court, 1992)
State v. Poblete
260 P.3d 1102 (Court of Appeals of Arizona, 2011)
State v. Tankersley
121 P.3d 829 (Arizona Supreme Court, 2005)
State of Arizona v. Darrel Peter Pandeli
394 P.3d 2 (Arizona Supreme Court, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Williams, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-williams-arizctapp-2026.