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Williams v. State

There was a substantial basis for the trial court's grant of the State's motion in limine preventing the defendant from cross-examining a detective about a statement that "police can and will lie," which was published on a website with which the detective was allegedly affiliated.

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Larry Eugene Williams was charged with nine drug-related counts1 arising out of three drug transactions on two different dates. Williams was convicted on all counts on March 4, 2009, but the trial court later granted his motion for new trial. On retrial, he was again convicted on all nine counts. Williams now appeals the denial of his subsequent motion for new trial, asserting that the trial court erred in granting the State’s motion in limine and in denying his motion for new trial despite what he asserts is a fatal variance between the allegations in the indictments2 and the evidence introduced at trial.

Viewed in the light most favorable to the verdict, the evidence showed that in June and July 2008, Brice Parrish was assisting Detective Josh Brock of the Summerville Police Department in making undercover purchases of controlled substances. On June 24, 2008, Parrish made two separate undercover purchases of a substance that contained cocaine from Williams. The next day, Williams again sold cocaine to Parrish during another controlled buy. Williams was later arrested and charged with the nine drug-related counts. Additional facts will be recited as necessary to consider Williams’ arguments.

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