State of Tennessee v. Charles L. Williams

This is a direct appeal as of right from convictions on a jury verdict of one count of child rape and two counts of rape. For these convictions, the Defendant, Charles L. Williams, received an effective twenty-two-year sentence in the Tennessee Department of Correction with 100% service required.  On appeal, the Defendant raises six issues: (1) the trial court erred in admitting hearsay testimony of the victim; (2) the evidence was insufficient to support the jury’s finding of guilt beyond a reasonable doubt on the charges of child rape and rape; (3) the trial court erred in allowing the State’s DNA expert witness to speculate about the significance of the ratio of DNA discovered under the Defendant’s fingernails; (4) prosecutorial misconduct requires a new trial; (5) the trial court gave erroneous jury instructions when it stated the elements of child rape could be satisfied by a showing of a mens rea of recklessness; and (6) the trial court erred in failing to merge the lesser rape convictions into the child rape conviction. We have concluded that the trial court erred by allowing certain speculative testimony by the State’s DNA expert witness. We also have concluded that the prosecutor engaged in misconduct during closing argument. In addition, the two rape convictions should have been merged into the child rape conviction. We have determined that the cumulative effect of the trial errors deprived the Defendant of a fair trial. Judge Welles also concludes that the trial court erred by giving erroneous jury instructions for the requisite mens rea. We reverse the convictions and remand for a new trial.