State v. Williams (1996)

State v. Williams, 321 S.C. 327, 468 S.E.2d 626 (1996), discusses the admissibility of third party guilt. Williams was convicted of murdering his wife and twelve-year-old adopted son. The victims were found inside the family van about six miles from their home. The front bumper of the van was against a tree, and fire had partially damaged the vehicle. The automobile accident had been staged. The accident scene and the autopsies revealed the victims were killed prior to the engineered car crash. Approximately one month before the murders, Williams substantially increased life insurance benefits on Wife and Son, designating himself as beneficiary. In addition, Williams upgraded existing policies with Allstate Insurance Company to include auto-related death benefits on both victims, forging his wife's name on the enrollment form. At trial, Williams proffered evidence that there were marijuana manufacturers in the area where the bodies were found who had subsequently threatened the lives of a confidential informant and a narcotics agent. Williams asserted these men had the motive and opportunity to kill the victims. The Circuit Court refused to allow this evidence and argument of the theory before the jury. On appeal, Williams claimed he had been denied an opportunity to create a reasonable doubt of his guilt. The Supreme Court disagreed: "After reviewing the record, we conclude that the evidence offered by Williams failed to establish that the persons arrested for growing marijuana had any connection whatsoever to the homicides. Hence, the drug offenses were isolated from the homicides, and evidence pertaining to them should not have been admitted to insinuate that someone other than Williams could have murdered the victims. Accordingly, because Williams failed to show that the proffered evidence was inconsistent with his guilt, the circuit court exercised sound discretion in excluding it." (Williams, 321 S.C. at 335, 468 S.E.2d at 631.)