State v. Williams

THIS OPINION HAS NO PRECEDENTIAL VALUE. IT SHOULD NOT BE
CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING
EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR.

THE STATE OF SOUTH CAROLINA
In The Court of Appeals

The State, Respondent,

v.

Tamika Yolanda Williams, Appellant.

Appellate Case No. 2022-000457

Appeal From Charleston County
Roger M. Young, Sr., Circuit Court Judge

Unpublished Opinion No. 2024-UP-091
Submitted January 1, 2024 – Filed March 20, 2024

AFFIRMED

Elizabeth Anne Franklin-Best, of Elizabeth Franklin-
Best, P.C., of Columbia, for Appellant.

Attorney General Alan McCrory Wilson and Senior
Assistant Attorney General Mark Reynolds Farthing,
both of Columbia; and Solicitor Scarlett Anne Wilson, of
Charleston, all for Respondent.

PER CURIAM: Tamika Yolanda Williams appeals her conviction for homicide
by child abuse and her sentence of twenty-five years' imprisonment. On appeal,
Williams argues the trial court erred by (1) admitting her inculpatory police
statement; (2) admitting color versions of the victim's autopsy photographs; and (3)
denying her motion for a directed verdict after the State failed to put forth evidence
of extreme indifference. We affirm pursuant to Rule 220(b), SCACR.

1. We find the trial court did not abuse its discretion in admitting the tape of
Williams's inculpatory police statements because Williams was advised of her
rights before the interview and the totality of the circumstances indicate her
statements were made voluntarily. See State v. Miller, 441 S.C. 106, 119, 893
S.E.2d 306, 313 (2023) ("[T]he question of voluntariness presents a mixed
question of law and fact."); id. ("[Appellate courts] review the trial court's factual
findings regarding voluntariness for any evidentiary support. However, the
ultimate legal conclusion—whether, based on those facts, a statement was
voluntarily made—is a question of law subject to de novo review."); State v.
Wallace, 440 S.C. 537, 542, 892 S.E.2d 310, 312 (2023) ("[A] trial court acts
outside of its discretion when the ruling is not supported by the evidence or is
controlled by an error of law."); Moran v. Burbine, 475 U.S. 412, 421 (1986)
("Miranda holds that '[t]he defendant may waive effectuation' of the rights
conveyed in the warnings 'provided the waiver is made voluntarily, knowingly and
intelligently.'" (alteration in original) (quoting Miranda v. Arizona, 384 U.S. 436,
444 (1966))); Miller, 441 S.C. at 120, 893 S.E.2d at 313-14 ("In analyzing whether
a defendant's will was overborne and the resulting confession was offensive to due
process, courts must consider the totality of the circumstances, including the details
of the interrogation and the characteristics of the defendant."); State v. Miller, 375
S.C. 370, 386, 652 S.E.2d 444, 452 (Ct. App. 2007) (stating appellate courts in
South Carolina have found appropriate factors to consider in the
totality-of-circumstances analysis to include "background, experience, and conduct
of the accused; age; length of custody; police misrepresentations; isolation of a
minor from his or her parent; threats of violence; and promises of leniency"); State
v. Anderson, 440 S.C. 124, 137–38, 889 S.E.2d 615, 622 (Ct. App. 2023) ("Absent
coercive police conduct causally related to a confession, there is no basis for
finding a confession constitutionally involuntary. A defendant's mental condition
in and of itself does not render a statement involuntary in violation of due process."
(quoting State v. Hughes, 336 S.C. 585, 594, 521 S.E.2d 500, 505 (1999))).

2. We find the trial court did not abuse its discretion in admitting the color
photographs from the victim's autopsy depicting his skull because they
corroborated witness testimony, were relevant to illustrate that the victim's injuries
were intentional and not accidental, and their probative value was not substantially
outweighed by the risk of unfair prejudice. See Rule 403, SCRE (stating relevant
evidence "may be excluded if its probative value is substantially outweighed by the
danger of unfair prejudice"); Wallace, 440 S.C. at 541-42, 892 S.E.2d at 312 ("We
will not reverse a trial court's ruling on an evidence question unless we find the
court abused its discretion, or . . . unless we find the trial court has not acted within
the discretion we grant to trial courts. . . . [A] trial court acts outside of its
discretion when the ruling is not supported by the evidence or is controlled by an
error of law."); State v. Collins, 409 S.C. 524, 534, 763 S.E.2d 22, 27 (2014) ("The
relevancy, materiality, and admissibility of photographs as evidence are matters
left to the sound discretion of the trial court." (quoting State v. Nance, 320 S.C.
501, 508, 466 S.E.2d 349, 353 (1996))); id. at 534, 763 S.E.2d at 28 ("A trial
judge's decision regarding the comparative probative value and prejudicial effect of
evidence should be reversed only in exceptional circumstances." (quoting State v.
Adams, 354 S.C. 361, 378, 580 S.E.2d 785, 794 (Ct. App. 2003))); State v.
Gilchrist, 329 S.C. 621, 627, 496 S.E.2d 424, 427 (Ct. App. 1998) ("Unfair
prejudice means an undue tendency to suggest [a] decision on an improper basis.");
State v. Torres, 390 S.C. 618, 623, 703 S.E.2d 226, 228 (2010) ("Photographs
calculated to arouse the sympathy or prejudice of the jury should be excluded if
they are irrelevant or not necessary to substantiate material facts or conditions.");
id. at 623, 703 S.E.2d at 229 ("[A]utopsy photographs may be presented to the jury
in an effort to show the circumstances of the crime and character of the
defendant."); State v. Nelson, 440 S.C. 413, 423, 891 S.E.2d 508, 513 (2023)
("[P]hotos should not be excluded on the ground they were gruesome when the
photos were 'highly probative, corroborative, and material in establishing the
elements of the offenses charged.'" (quoting Collins, 409 S.C. at 535, 763 S.E.2d at
28)); State v. Heyward, 441 S.C. 484, 502-04, 895 S.E.2d 658, 668-69 (2023)
(affirming the admission of autopsy photographs when the photographs illustrated
a contested point at trial).

3. We hold the trial court properly denied Williams's motion for directed verdict
because, when viewing the evidence in the light most favorable to the State, the
State presented substantial circumstantial evidence that demonstrated Williams
committed child abuse under circumstances manifesting extreme indifference to
human life, which led to the death of the victim. The State presented evidence
showing the victim's injuries were intentional and Williams was the only person
awake and capable of inflicting the injuries at the time of the incident. See State v.
Smith, 359 S.C. 481, 491-92, 597 S.E.2d 888, 894 (Ct. App. 2004) (finding there
was substantial circumstantial evidence when there was evidence the victim
sustained several intentional injuries and defendants were the only people present
who could have inflicted them). Additionally, the State presented Williams's
interview with police in which she gave contradicting accounts of what happened
in the hours after the victim's death, including admissions that she dropped the
victim. See State v. Weston, 367 S.C. 279, 292, 625 S.E.2d 641, 648 (2006)
("When reviewing a denial of a directed verdict, [an appellate c]ourt views the
evidence and all reasonable inferences in the light most favorable to the [S]tate.");
State v. Zeigler, 364 S.C. 94, 101, 610 S.E.2d 859, 863 (Ct. App. 2005) ("When
ruling on a motion for a directed verdict, the trial court is concerned with the
existence or nonexistence of evidence, not its weight."); State v. Harris, 342 S.C.
191, 203, 535 S.E.2d 652, 658 (Ct. App. 2000) ("If the State presents any evidence
which reasonably tends to prove the defendant's guilt or from which the
defendant's guilt could be fairly and logically deduced, the case must go to the
jury."); Zeigler, 364 S.C. at 102, 610 S.E.2d at 863 ("If there is any direct evidence
or any substantial circumstantial evidence reasonably tending to prove the guilt of
the accused, an appellate court must find the case was properly submitted to the
jury.").

AFFIRMED.1

MCDONALD and VINSON, JJ., and LOCKEMY, A.J., concur.

1
We decide this case without oral argument pursuant to Rule 215, SCACR.