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Williams v. State

The defendant sold marijuana to an undercover officer and spat in another officer's face after his arrest.

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After a bench trial, Robert Williams was found guilty of one count of selling marijuana and one count of simple battery. On appeal, he challenges the sufficiency of the evidence and contends that the trial court erred in admitting similar transaction evidence. For reasons that follow, we affirm. 1. On appeal from a criminal conviction after a bench trial, “we view the evidence with all inferences in favor of the factfinder’s conclusion, giving due regard to the trial court’s opportunity to judge witness credibility.”1 So viewed, the evidence shows that on the night of March 26, 2005, Williams was sitting on the porch of a house in Savannah. An undercover narcotics officer was walking past the house when Williams called out to the officer that he had “some good weed.” The officer sat down next to Williams on the porch and Williams showed him “a small amount of green leafy material which later field tested positive for marijuana.” Williams offered to sell some marijuana to the officer for seven dollars. The officer left, obtained seven dollars in marked money, returned to the porch, and purchased the marijuana from Williams. The transaction was observed by other officers, and Williams was immediately arrested. The marked money was in Williams’s hand when he was arrested.

After his arrest, Williams was “very disorderly,” yelling and screaming profanity at the officers who were preparing to transport him to jail. While in the transport vehicle, he spat upon other occupants. When a female officer attempted to remove Williams from the vehicle, he spat in her face.

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