CourtListener 10845984

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official text of the opinion.

In the Supreme Court of Georgia

Decided: March 17, 2026

S26A0389. WILLIAMS v. THE STATE.

PINSON, Justice.

Ryan Christopher Williams was convicted of felony murder and

other crimes in connection with the death of Kris Holt. 1 On appeal,

he contends that the trial court abused its discretion by denying his

1 Williams beat Holt with a metal implement and then a baseball bat on

July 18, 2018, and Holt died on March 13, 2019. On June 14, 2019, a Fulton
County grand jury indicted Williams for malice murder (Count 1), felony mur-
der predicated on aggravated assault (Count 2), felony murder predicated on
aggravated battery (Count 3), aggravated assault (Count 4), aggravated bat-
tery (Count 5), and criminal damage to property in the second degree (Count
6). Williams was tried by a jury from December 12 to 19, 2022. The jury found
Williams not guilty of malice murder but guilty of the remaining charges. The
trial court sentenced Williams to life in prison for felony murder predicated on
aggravated assault and five years in prison for criminal damage to property in
the second degree, to be served consecutively. The remaining charges merged
for sentencing or were vacated by operation of law. Williams filed a timely mo-
tion for new trial, which he later amended through new counsel. The trial court
held an evidentiary hearing on the motion for new trial and then denied the
motion on January 2, 2025. Williams filed a timely notice of appeal directed to
the Court of Appeals, which transferred the appeal to this Court on Septem-
ber 11, 2025. The case was docketed to the term of this Court beginning in
December 2025 and submitted for a decision on the briefs.
motion for continuance, that the State committed prosecutorial mis-

conduct by failing to turn over certain evidence until the eve of trial,

that trial counsel gave ineffective assistance by failing to preserve

the claim of prosecutorial misconduct for appellate review, and that

the trial court gave a jury instruction (which Williams does not spec-

ify) that improperly told the jury how to resolve conflicts in the evi-

dence.

These claims fail. Williams has not shown any evidence that

the trial court’s denial of a continuance affected his defense. The

claim of prosecutorial misconduct is not preserved for appeal. Trial

counsel did not perform deficiently by failing to assert the prosecu-

torial-misconduct claim in the trial court and thus failing to preserve

it for appeal, because the claim was meritless: there is no evidence

of actual misconduct by the State. Finally, Williams does not specify

what jury instruction he challenges, so he has not met his burden of

showing error on that claim. So Williams’s convictions are affirmed.

1. The evidence at trial showed the following. In the early

morning hours of July 18, 2018, Williams’s upstairs neighbor was

2
awakened by a “commotion.” The neighbor jumped out of bed, went

to his balcony, and saw Williams in the street “beating on” another

man with a bat. The victim — later identified as Holt — was in a

parked car with a shattered windshield, and Williams was pulling

him out. Williams was yelling, at the top of his lungs, “[B]**ch a**

n**ger. I told you to stop f**king playing with me. I told you the day

was coming. I don’t know why I’m the one you’re playing with. I’m

f***ing Rock Star. You gonna stop playing with me.” Holt was

screaming for help.

Eventually Williams let Holt go. Holt was stumbling and “dis-

combobulated,” but he got back into his car and started to drive

away. The neighbor called 911 — the call came in at 3:14 a.m. —

because he could tell from the way Holt was driving that “he wasn’t

going to make it far.” In the aftermath, Williams, who was spattered

with blood, swept up the broken glass and picked up Holt’s phone

from the ground and threw it in the trash. At that point Williams

said to the neighbor, “I apologize. You guys know I get F’d up some-

times.”

3
Holt made it home, called 911 from his watch, and was taken

to the hospital. When a police officer arrived at the hospital, Holt

appeared “severely injured” and lethargic, and he spoke slowly. Holt

was able to tell the officer that the assailant was “Rock Star,” which

was Williams’s nickname in the neighborhood.

Police contacted Williams, who agreed to an interview. After

waiving his Miranda 2 rights, Williams told police that Holt had

come to his home to “get some drugs” from a dealer Williams knew.

Holt had promised to pay Williams a fee after the transaction. But

when the two returned to Williams’s home after buying the drugs,

Holt suggested that Williams have sex with him instead. Williams

got angry and threw a drink at Holt. Holt then attacked Williams

with a metal implement that he had in his car. Williams, however,

took the implement away and started to beat Holt. Then Williams

got a baseball bat and “beat him some more.” Along with his inter-

view, Williams prepared a written statement that was largely con-

sistent with his interview. Later, at trial, Williams testified in his

2 Miranda v. Arizona, 384 US 436 (1966).

4
own defense and gave substantially the same account.

Holt died eight months after the attack, on March 13, 2019,

and Williams was charged with his murder. At trial, the State intro-

duced testimony from medical experts to connect Holt’s death to his

head injury eight months earlier. The doctor who treated Holt the

night he was attacked testified that Holt arrived at the hospital with

a “very severe” traumatic brain injury. The doctor testified that the

emergency procedures he and his team performed on Holt — includ-

ing inserting a breathing tube and removing a part of Holt’s skull to

relieve brain swelling — “saved his life that night.” The State also

called the emergency room doctor who had treated Holt on the night

he died. That doctor said that Holt was brought in after having a

seizure at home, and that he was unresponsive and in cardiac arrest.

Finally, the medical examiner who performed the autopsy testified

that seizures can be a result of a traumatic brain injury, and that

Holt’s brain showed evidence of such an injury, including discolora-

tion, scarring, and encephalomalacia, or a “softening” of the brain.

5
Based on her autopsy and on Holt’s records from his initial treat-

ment and rehabilitation, the medical examiner determined that the

case was a homicide. The cause of death was a seizure brought on

by a traumatic brain injury caused by blunt force trauma.

Williams called his own expert to rebut the State’s witnesses.

Williams’s expert, a retired forensic pathologist, testified that Holt

likely died from a heart attack not related to the beating. Holt had

high blood pressure that was not well treated and that had caused

kidney damage. The pathologist said that on the night Holt died, the

accumulated effects of high blood pressure caused a sudden “heart

rhythm disturbance” in which Holt’s heart rate and blood pressure

deteriorated to an unsurvivable level. The pathologist further testi-

fied that Holt’s seizure on the night he died could have been a part

of his body’s response to the cardiac arrest as his brain was “not get-

ting enough oxygen,” which is a “very common” occurrence, and not

related to a traumatic brain injury. He testified that what the State

alleged happened — cardiac arrest brought on by a seizure whose

root cause was a head injury suffered more than a few weeks earlier

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— is “vanishingly rare.”

2. Williams contends that the trial court should have granted

a continuance to give the defense expert time to review certain med-

ical records that the defense received only days before trial. The de-

cision whether to grant a continuance is “addressed to the sound le-

gal discretion of the court.” OCGA § 17-8-22. See also Harris v. State,

314 Ga. 370, 373 (2022). And to obtain a new trial based on the de-

nial of a continuance, an appellant must show not only that the trial

court abused that discretion, but also that he was “harmed by that

denial.” See Blalock v. State, 316 Ga. 330, 338 (2023).

(a) On the first day of trial, Williams moved for a continuance.

Williams contended that the medical records that the State had pro-

vided to the defense in discovery were not complete until three days

before trial. According to Williams, the defense had been asking the

State for records from Holt’s treatment at the hospital on March 13,

2019, the day he died, but the State repeatedly told the defense that

the records did not exist. Finally, on the Friday afternoon before the

7
Monday when the trial was set to begin, the State provided the miss-

ing March 13 records. In Williams’s view, the missing records were

exculpatory, and the State’s failure to provide them earlier was a

Brady 3 violation. Williams contended that the trial must be contin-

ued so that the defense expert could review the new records and so

that the defense could subpoena witnesses referenced in the records.

Williams also noted that the defense expert was not available to tes-

tify in person during the trial as it was then scheduled, and he ar-

gued that it would be prejudicial for the defense expert to testify by

videoconference when the State’s experts were all in person. The

trial court denied the motion to continue.

After Williams was convicted, at the hearing on his motion for

a new trial, the trial prosecutor testified about his “several months”

of efforts to get the missing records. The prosecutor subpoenaed the

records, emailed and called the hospital, and checked the file at the

medical examiner’s officer, and he was repeatedly told the records

did not exist. The prosecutor also went to the hospital in person more

3 Brady v. Maryland, 373 US 83 (1963).

8
than once. The second time he went, he waited for “several hours”

and told the hospital’s records department that he would not leave

until he had either the records or a written representation that they

did not exist. On that occasion, the hospital finally provided the

missing records, which consisted of “eight or nine pages.” The pros-

ecutor then turned the records over to the defense within 30 minutes

of getting them. The prosecutor also testified that it did not appear

that the defense had made any attempt to get the missing records,

although it had the same access to the records as the State did.

(b) Even assuming that the trial court abused its discretion in

denying Williams a continuance to review the new medical records,

Williams’s claim fails because he has not shown that he was harmed

by that denial. He argues that the defense expert needed more time

to review those records to inform his opinion, and that trial counsel

needed more time to investigate potential witnesses revealed by the

new records. But as the State correctly points out, Williams does not

support with any evidence his claim that his defense was affected by

the late disclosure of the missing pages of medical records. He has

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not explained how his expert’s analysis, conclusions, or testimony

would have been different if the expert had been given extra time to

review that handful of pages. Nor has he identified what additional

witnesses were named in the pages that he would have called, much

less established with evidence what those witnesses would have said

at trial. And he has not shown how trial counsel was impaired in her

cross-examination of State witnesses, because trial counsel did not

testify at the motion-for-new-trial hearing and no other evidence on

this point was presented. In short, Williams has not shown any evi-

dence that his defense was affected in any of the ways he claims (or

any other way) by the denial of a continuance. Without that show-

ing, his claim fails. See Blalock, 316 Ga. at 339 (denial of continu-

ance did not harm defendant where defendant did not show that ex-

pert testimony would have helped him formulate an effective de-

fense or how the testimony would otherwise have benefitted him at

trial); Phoenix v. State, 304 Ga. 785, 789 (2018) (to show harm from

the denial of a continuance, a defendant must identify what other

evidence or witnesses he would have put forth if given more time,

10
and “speculation and conjecture are not enough” (citation omitted));

Geiger v. State, 295 Ga. 648, 651 (2014) (defendant did not show he

was harmed by denial of a continuance to get shell casing inde-

pendently tested when the defendant also failed to get the shell cas-

ing tested before the motion-for-new-trial hearing and thus could

not show what testing would have revealed).

3. In a related claim, Williams contends that, to the extent the

State intentionally failed to disclose the March 13 medical records

until the eve of trial, the State committed prosecutorial misconduct.

But Williams did not raise any such claim in the trial court, and

unraised claims of prosecutorial misconduct are not reviewed for

plain error. See Callaway v. State, 321 Ga. 186, 193 (2025); Grissom

v. State, 296 Ga. 406, 411–12 (2015). So this claim is not preserved

for our review on appeal.

4. In his third claim related to the March 13 medical records,

Williams contends that his trial counsel gave constitutionally inef-

fective assistance by failing to raise a claim of prosecutorial miscon-

duct based on the State’s late disclosure of those records. To prevail

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on a claim on ineffective counsel, a defendant must show both that

counsel’s performance was professionally deficient and that he suf-

fered prejudice as a result. See Strickland v. Washington, 466 US

668, 687 (1984); Washington v. State, 313 Ga. 771, 773 (2022). To

show deficiency, the appellant must show that his lawyer performed

“in an objectively unreasonable way,” Heyward v. State, 319 Ga. 588,

592 (2024) (quotation marks omitted), which generally means show-

ing that “no reasonable lawyer would have done what his lawyer did,

or would have failed to do what his lawyer did not,” Evans v. State,

315 Ga. 607, 611 (2023) (quotation marks omitted). To show preju-

dice, a defendant must show that, but for counsel’s deficient perfor-

mance, there was a “reasonable probability” that the result of the

trial would have been different. Heyward, 319 Ga. at 592 (quotation

marks omitted).

Williams contends his counsel should have raised a claim of

prosecutorial misconduct in the trial court. To prevail on such a

claim, Williams would have had to show both “actual misconduct”

and “demonstrable prejudice to his right to a fair trial.” Cushenberry

12
v. State, 300 Ga. 190, 195 (2016). And to show prosecutorial miscon-

duct of the type that Williams alleges here — the State’s withholding

of exculpatory evidence from the defense, in violation of Brady v.

Maryland, 373 US 83 (1963) — a defendant must show that (1) the

State had evidence favorable to the defense, (2) the defense did not

have the evidence and could not have obtained it “with any reason-

able diligence,” (3) the prosecution suppressed the evidence, and

(4) had the evidence been disclosed to the defense, “a reasonable

probability exists that the outcome of the proceeding would have

been different.” Sauder v. State, 318 Ga. 791, 807 (2024) (quotation

marks omitted). See also Brady, 373 US at 87 (“[T]he suppression

by the prosecution of evidence favorable to an accused upon request

violates due process where the evidence is material either to guilt or

to punishment, irrespective of the good faith or bad faith of the pros-

ecution.”).

Under those standards, any claim of prosecutorial misconduct

based on the late production of the March 13 medical records would

have failed. The evidence showed that the State did not withhold the

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missing medical records or delay giving them to the defense. To the

contrary, over a period of months, the prosecutor tried to get the rec-

ords through several different methods, was consistently told they

did not exist, and finally got them only when he went to the hospital

and refused to leave without them. And then, once the State finally

had the March 13 records, it gave them to the defense right away.

In short, the record shows that the State acted properly and ethically

with respect to the March 13 records. And Williams points to no

other evidence that might suggest “actual misconduct” on the State’s

part, see Cushenberry, 300 Ga. at 195, or evidence that the State

deliberately withheld exculpatory evidence, see Sauder, 318 Ga. at

807. Without any evidence of misconduct, a claim of prosecutorial

misconduct would have been meritless.

Because counsel does not perform deficiently by failing to raise

a meritless claim, see, e.g., Johnson v. State, 310 Ga. 685, 691–92

(2021), this claim of ineffective assistance of counsel fails.

5. Finally, Williams contends that the trial court erred by in-

structing the jury on how to resolve conflicts in the evidence. But

14
Williams does not identify the jury instruction he purports to chal-

lenge, either by pointing us to the instruction in the record or even

by simply telling us what it is. He says only that some unspecified

instruction from the trial court “impermissibly invaded the province

of the jury and improperly influenced the jury’s evaluation of dis-

puted evidence,” and then he cites one decision of this Court that

does not help point us to the instruction he means. It is the appel-

lant’s burden to show error by identifying in the record the thing

that he challenges on appeal and citing authority to show why that

thing represents an error. See Hornbuckle v. State, 300 Ga. 750, 753

(2017) (“‘The appellant bears the burden of proving error by the ap-

pellate record.’”); Young v. State, 232 Ga. 285, 290 (1974) (“The bur-

den of showing error is upon the appellant.”). See also Jacobs v.

State, 306 Ga. 571, 575 (2019) (“[I]t is not this Court’s responsibility

to cull the record to find support for a defendant’s claims.”). By fail-

ing to identify in any way the specific jury instruction that he chal-

lenges, Williams has failed to meet that burden, and so this claim

15
fails. 4

Judgment affirmed. All the Justices concur.

4 Williams does not raise a separate claim of cumulative error, but he

does refer to the cumulative effect of his claims of error in the last sentence of
the introduction to the argument section of his brief. In any event, any such
claim would fail because Williams has not established multiple errors. See,
e.g., Williams v. State, 318 Ga. 83, 97 (2024).
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