State v. Williams

Antoine Williams (defendant) was charged with assault and unlawful possession of a firearm by a felon. Witnesses had identified Williams as the suspect, but Williams denied being involved. In the two years before this event, Williams had twice been convicted of drug crimes. Before trial, the court applied a five-factor test and found that (1) the two prior drug convictions had impeachment value because they helped to draw a picture of who Williams was as a whole person; (2) the recency of the convictions showed that Williams had developed a pattern of lawlessness; (3) the dissimilarity between the prior and current crimes reduced the likelihood that a jury would misuse the prior convictions as propensity evidence; (4) the threat of impeachment might prevent Williams from testifying, but this harm was minimal because Williams could present his defense without testifying; and (5) the impeachment evidence was probative because witness credibility was part of the identification issue. All five findings weighed in favor of admitting the prior convictions, and the court ruled that the prior convictions could be used to impeach Williams if he testified. Williams did testify and presented the prior-conviction evidence on direct examination in order to avoid looking as though he were hiding the information. Williams was convicted and appealed. On appeal, Williams argued that the evidence of his prior drug-crime convictions should have been excluded as more prejudicial than probative of his truthfulness.