Williams v. State

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In the
Supreme Court of Georgia
No. S26A0491
Jaye Alexander Williams
v.
The State

On Appeal from the Superior Court of Richmond County
No. 2018-RCCR-395

Decided: May 19, 2026

ELLINGTON, Justice.
Jaye Alexander Williams appeals his convictions for malice
murder and possession of a firearm during the commission of a
crime in connection with the shooting death of Robert Lee Brown,
Jr. 1 Williams contends that the evidence was constitutionally
insufficient to support his convictions and that his trial counsel
provided constitutionally ineffective assistance. For the reasons

1 The crimes occurred on December 26, 2017. On March 20, 2018, a
Richmond County grand jury indicted Williams for malice murder, felony
murder, and possession of a firearm during the commission of a crime. After a
jury trial that ended on March 28, 2019, Williams was found guilty on all
counts. On that same day, Williams was sentenced to serve life in prison
without the possibility of parole for malice murder and a consecutive five-year
prison term for the firearms count. The felony murder count was vacated by
operation of law. Williams filed a timely motion for new trial, which he
amended through new counsel on March 3, 2022, and September 19, 2024. The
trial court denied Williams’s amended motion for new trial on July 1, 2025.
Williams filed a timely notice of appeal, and the case was docketed in this
Court to the term beginning in December 2025 and submitted for a decision on
the briefs.
explained below, we affirm.
1. Viewed in the light most favorable to the verdicts, the
evidence presented at trial showed that Williams drove Brittany
Woods, the mother of Brown’s child, to Brown’s house and
subsequently killed Brown by shooting him three times, including
twice in the back.
Woods and Brown had previously lived together, but the
relationship was “toxic,” and after they broke up, Woods
threatened to kill Brown. On December 25, 2017, Brown was with
his girlfriend, Quanda Lane, at his house, where he lived with his
cousin Joe Wright. Williams drove Woods and her infant son to
Brown’s house around midnight. Lane, Wright, and a neighbor
heard Woods yelling and cursing outside the home and
demanding that Brown wake up and come out. Woods banged on
the doors and windows with a mop handle, breaking the window
where Brown was sleeping. At one point, Woods took her
screaming infant from the back seat of Williams’s car and yelled
for Brown to come get his son.
Wright told Brown to stay inside, left the house, and asked
Woods to leave. Shortly thereafter, Wright left the house to give
another cousin a ride to meet a friend. Lane testified that Brown
went outside to see if he could calm Woods down. When Wright
returned about ten minutes later, he saw Brown outside picking
the shirtless infant up off the ground and walking toward
Williams’s car. While Brown was putting the child into Williams’s
car, Wright heard Brown say to Woods “what’s wrong with you,
you got this baby out here in this cold and he’s going to get sick.”
Wright did not see anyone else present or anyone fighting at that
point.
Wright retrieved his cigarettes from his car and began to
walk toward his house when he heard four gunshots. Wright saw

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a young man shooting at Brown as Brown held up his hand,
saying “man, what are you doing?” and “why you shoot me[?] Why
are you trying to kill me?” Wright heard Williams say “you f**k
n****r, I was waiting on you to come out the house.” Wright then
jumped over the fence to escape being shot himself and heard
Woods say to Williams, “I told you to hurt him, not kill him.”
Wright immediately called the police and gave a statement that
night.
Lane testified that she heard the gunshots about 15 to 20
minutes after Brown went outside. From a nearby residence,
Joquinn Turner heard Woods’s yelling and saw her take the
infant out of the car. Turner did not hear a male’s voice or see any
confrontation between any males before she went inside. About
three to four minutes after going inside, Turner heard the
gunshots and saw a man run from the scene of the shooting.
Turner heard Woods yell for someone to call the police and then
say to Brown “oh my God, baby, I’m sorry, I’m sorry, he wasn’t
supposed to do this. He was only supposed to hurt you, he was
only supposed to hurt you, he wasn’t supposed to do this.” When
Turner went to help, Woods said that “her best friend’s brother”
shot Brown because Brown was supposed to spend Christmas
with Woods and their son but she had just found out that Brown
was cheating on her.
Brown died at the hospital from gunshot wounds to the
center of his back, to his upper chest, and to his left buttock. Police
located four shell casings near Williams’s car and saw blood on
the trunk of the car, the passenger side of the car and near the
front wheel of the car on the ground. No guns were found at the
scene or inside Brown’s house. Inside the car was a black gun
lockbox containing ammunition similar to the spent casings.
Williams contacted his mother claiming he had been in a

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shootout. She promptly called the police shortly after 1:00 a.m.,
and Williams was taken into custody without incident at 1:45 a.m.
An investigator spoke to Williams, reviewed his Miranda rights
with him, and obtained his signature at 3:44 a.m., and noted that
Williams had no visible injuries or signs of having been in a
physical altercation.. Williams told the investigator that, because
Brown attacked him and “swung at” him and Woods, he shot
Brown several times from about five yards away even though
Williams saw no weapon. Williams claimed that Brown yelled out,
“I’ve got guns in the house, and I’m gonna kill everybody out
here.” Williams told the investigator that he felt like his life was
in danger, so he did what he felt was right to protect himself,
Woods, and the infant. Williams said he ran from the scene after
the shooting because he thought someone else was going to shoot
back at him. After Williams called his mother, he threw the gun
away as he ran. He was unable to lead the police to the gun, and
it was never recovered.
Williams testified at trial as follows. He denied any
romantic relationship with Woods, who was his sister’s best
friend. He claimed he was just giving her and her infant son a ride
home from a party that night. But when they left the party,
Woods immediately asked Williams to drive her to Brown’s house
instead of her home because she and Brown were supposed to
open Christmas gifts together. Williams asked “are you sure? It’s
a little late.” Woods tried to call Brown, who did not answer, but
she still wanted to go to his house, and Williams agreed to take
her there. Williams testified that he “did not give it any second
thought” because sometimes he would go to other people’s houses
or they would come to him in the middle of the night.
When they arrived at Brown’s house, Williams testified
that he remained in the car for about an hour. He testified that

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he was shocked at Woods’s behavior there, as she had never really
gotten loud before, and he urged her to get back in the car so they
could leave. Williams saw Woods physically punch Brown’s face,
“swinging at him like Mike Tyson,” but at that time did not see
Brown swing back at Woods, and he did nothing to intervene
because the “situation” had “nothing to do with” him. Williams
did not consider calling 911 because everything “started to calm
down.”
According to Williams, he got out of the car to take the
infant to Woods but returned to the car with the child. He was
trying to calm the screaming infant down when he felt the car
rock and saw that Brown was holding Woods up against the car
and that Woods had ripped Brown’s shirt. Williams testified that
Brown “brought [him] into the situation” when Brown threatened
“you know what I do, I have guns in the house, I’ll kill everybody
out here.” Williams, having never been threatened like that
before, grabbed his black box with his Smith & Wesson .40-caliber
handgun, loaded it, slipped it into his pocket, and got out of his
car. Williams saw another car pull into the driveway and saw
someone get out. Williams heard Brown say, “Rob or Joe, if he
touches me, kill him,” and Brown then took off his ripped shirt
and threw it to the ground.
Williams further testified that Brown first began striking
Woods and then “came at [him], swinging,” striking him at least
two times including once in the face. But Williams admitted he
did not tell the investigator that Brown had punched him in the
face when he was interviewed three hours after the murder.
Williams claimed that he was bleeding a little from his mouth and
had a cut on his hand from blocking punches. When asked why he
pulled out his gun, Williams stated, “I felt that my life was in
danger with him threatening me and also telling someone else to

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cause me harm if I was to touch him” and “it was dark, and I didn’t
know if he had a weapon stashed in his pants or a knife or
anything of that nature.” Williams admitted that he never saw a
gun in Brown’s hand.
Williams did not try to calm Brown down or tell him that
he just wanted to leave, nor did Williams tell Brown to back off,
tell him that he had a gun, show him the handgun, or say
anything to Brown. Williams testified that he was backing away
from Brown as Brown was hitting him and that he then pulled
his gun from his pocket and shot Brown multiple times. Williams
denied thinking Brown was going to get a weapon, claimed not to
know if Brown had a weapon, and admitted that he shot Brown
because of the verbal threats. Williams denied that he threatened
Brown or that he and Woods had a plan to harm Brown or scare
him. When asked why he fired four times at Brown, Williams said
he did so to defend himself and did not decide to shoot a particular
number of times. And when asked why he fled, Williams said he
panicked and did not know if a second person was going to come
after him. Williams did not know that he had shot Brown in the
back, as everything happened quickly. Williams stated that he
simply dropped his handgun as he ran from the shooting and did
not stop to pick it up. Williams did not attempt to call 911 after
the shooting but did call three other persons. Williams testified,
“I defended myself because [Brown] attacked me after giving two
threats,” and “Had I not defended myself, I could have died.”
Williams contends that the evidence was constitutionally
insufficient to support his convictions because the State did not
disprove self-defense beyond a reasonable doubt. “We evaluate a
due process challenge to the sufficiency of the evidence by viewing
the evidence presented at trial in the light most favorable to the
verdicts, and asking whether any rational trier of fact could have

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found the defendant guilty beyond a reasonable doubt.” Whisnant
v. State, 322 Ga. 253, 257 (2025) (quotation marks omitted).
“Conflicts or inconsistencies in the evidence, credibility of
witnesses, and reasonable inferences to be derived from the facts
are for the jury to resolve.” Id. (citation and punctuation omitted).
“When a defendant presents evidence that he was justified in
using deadly force, the State bears the burden of disproving the
defense beyond a reasonable doubt.” Allen v. State, 322 Ga. 417,
422 (2025) (quotation marks omitted). “But it is the role of the
jury to evaluate the evidence and decide whether the defendant
was justified in using deadly force in self-defense.” Maynor v.
State, 317 Ga. 492, 497 (2023) (quotation marks omitted). And
“when doing so, the jury is free to reject any evidence in support
of a justification defense and to accept the evidence that the
defendant did not act in self-defense.” Allen, 322 Ga. at 423
(quotation marks omitted). Under OCGA § 16-3-21(b)(3), “a
person is not justified in using force in self-defense if he was the
aggressor.” Maynor, 317 Ga. at 497 (citation and punctuation
omitted).
Williams argues at some length that his account of the
shooting—including threats, menaces, and attacks by Brown—
was not inconsistent with certain evidence presented by the State
and showed Williams’s reasonable belief that deadly force was
necessary to prevent death or great bodily harm. But the jury was
free to reject Williams’s self-serving testimony that Brown
attacked him and Woods first, especially when it was the only
such evidence and was inconsistent with the eyewitness
testimony. See Allen, 322 Ga. at 423 (holding that the evidence
was sufficient to authorize the jury to find beyond a reasonable
doubt that the appellant did not act in self-defense where his self-
serving testimony was inconsistent with his prior admissions and
with the testimony of multiple eyewitnesses); Maynor, 317 Ga. at

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497–98 (holding that the evidence was constitutionally sufficient
to disprove the appellant’s self-defense claim beyond a reasonable
doubt where his self-serving testimony—that the victim tried to
hit him with a car, verbally instigated a fight, and was armed—
was the only evidence supporting his affirmative defense and was
inconsistent with the other eyewitness accounts). Moreover, “the
jurors were also authorized to consider their disbelief in
[Williams’s] testimony—and the inconsistencies between it and
the eyewitness accounts of others—as substantive evidence of his
guilt.” Maynor, 317 Ga. at 498. The evidence therefore was
constitutionally sufficient for the jury to find beyond a reasonable
doubt that the State disproved self-defense.
2. Williams also contends that his trial counsel provided
constitutionally ineffective assistance when she failed to
investigate and present evidence supporting voluntary
manslaughter as an alternative defense theory and when she
failed to request a jury charge on voluntary manslaughter.
Assuming without deciding that Williams preserved these issues
for review, we see no merit in this contention for the following
reasons.
To prevail on a claim of ineffective assistance of counsel, a
defendant must show that his counsel’s performance was
deficient and that the deficient performance prejudiced him.
Strickland v. Washington, 466 US 668, 687 (1984). To satisfy the
deficiency prong of the Strickland test, a defendant must
demonstrate that trial counsel “performed at trial in an
objectively unreasonable way considering all the circumstances
and in the light of prevailing professional norms.” Butler v. State,
313 Ga. 675, 683 (2022) (quotation marks omitted). To prove
prejudice under Strickland, a defendant must demonstrate “a
reasonable probability that, but for counsel’s deficiency, the result

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of the trial would have been different.” Burke v. State, 320 Ga.
706, 708 (2025) (quotation marks omitted). And, if a defendant
fails to make a sufficient showing on one prong of the Strickland
test, we need not address the other prong. Starks v. State, 320 Ga.
300, 304 (2024).
OCGA § 16-5-2(a) defines “voluntary manslaughter” as the
killing of another person under circumstances that would
otherwise be murder when the killer “acts solely as the result of
a sudden, violent, and irresistible passion resulting from serious
provocation sufficient to excite such passion in a reasonable
person.” “To warrant a jury charge on voluntary manslaughter,
there must be at least slight evidence that the accused was so
influenced and excited that he reacted passionately rather than
simply in an attempt to defend himself.” Stapleton v. State, 323
Ga. 380, 388 (2026) (quotation marks omitted).
Williams primarily argues that his trial counsel failed to
investigate and present evidence about his mental health—which
he asserts was relevant to voluntary manslaughter—related to
his father’s childhood abuse of him and his sister, his military
service, and his potential PTSD. However, even if such mental
health evidence had been presented at trial, it could not have
provided any support for a verdict of voluntary manslaughter.
“[W]e must evaluate the alleged provocation evidence with
respect to its effect on a reasonable person, putting aside any
peculiar response Appellant may have had.” Johnson v. State, 297
Ga. 839, 842 (2015). Thus, “this Court has consistently held that
evidence of a defendant’s subjective mental condition or mental
illness is not relevant to a claim of voluntary manslaughter.”
Collins v. State, 306 Ga. 464, 467 (2022). See also Riggs v. State,
306 Ga. 759, 763 (2019) (holding that evidence of “an alleged
incident [of sexual abuse] occurring many years earlier ... was

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simply not relevant to the jury’s determination regarding
voluntary manslaughter,” and “in the absence of an insanity
defense ... , [the defendant] cannot demonstrate that this evidence
was relevant to show his alleged subjective mental state”);
Johnson, 297 Ga. at 842–43 (citing cases holding that the
defendant’s “fragile mental state” or psychological evidence about
the effect of the victim’s conduct on the defendant’s mental state
at the time of the killing was irrelevant to a voluntary
manslaughter defense). In light of these precedents, efforts to
investigate and present evidence related to Williams’s abuse and
PTSD allegations “in the hope of obtaining a jury instruction on
voluntary manslaughter would have been a waste of time, and
trial counsel’s failure to do so was therefore neither deficient nor
prejudicial.” Collins, 306 Ga. at 467.
Williams also claims that the evidence presented at trial
warranted a charge on voluntary manslaughter and that trial
counsel’s failure to request such a charge amounted to ineffective
assistance. We disagree. “A charge on voluntary manslaughter is
not available to a defendant whose own statement unequivocally
shows that he was not angered or impassioned when a killing
occurred, and when the other evidence does not show otherwise.”
Stapleton, 323 Ga. at 388 (quotation marks omitted). Williams
“never testified that he was angry or mad or that he had any other
response showing he might have reacted passionately.” Id.
(quotation marks omitted). Instead, he consistently claimed that
his life was in danger and he shot Brown to defend himself.
Williams’s story about Brown’s threats and attacks furnish some
support for Williams’s self-defense claim but not for voluntary
manslaughter. See id. (“Acting out of fear of bodily harm is not
the same as acting in the heat of passion, and only evidence of the
latter supports a voluntary manslaughter conviction.” (citation
and punctuation omitted)); Anderson v. State, 319 Ga. 56, 61

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(2024) (“[T]hreats and insults on their own are not enough to
support a voluntary manslaughter instruction.”); Smith v. State,
296 Ga. 731, 737 (2015) (“[N]either fear that someone is going to
pull a gun nor fighting are the types of provocation which demand
a voluntary manslaughter charge.”). “Trial counsel was not
deficient for failing to request a charge on voluntary
manslaughter because there was no evidence to support the
charge.” Powell v. State, 307 Ga. 96, 105 (2019).
Judgment affirmed. All the Justices concur, except Warren,
P.J., not participating.

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