## Facts

- Charles Williams was tried in a Texas district court for robbery by firearm arising from an October 24, 1973 incident at a liquor store in Houston.
- The complainant, the store manager, testified Williams entered the store with a pistol, demanded money, forced her to lock the doors, and raped her, then threatened to kill her and her baby if she contacted police.
- Williams testified and denied committing robbery or rape, asserting he had a consensual relationship with the complainant and claiming he was in Louisiana on the offense date.
- In rebuttal, the complainant denied any relationship and testified that six days later Williams confronted her with butcher knives and raped her again after accusing her of calling police.
- Williams had court-appointed counsel but filed multiple pro se motions and conducted much of his own defense, including witness examinations.
- The jury convicted Williams and assessed 25 years’ imprisonment.

## Issues

1. Whether the trial court erred by failing to grant a mistrial after the complainant referenced a prior extraneous offense involving Williams.
2. Whether the trial court was required to excuse or correct Williams’s procedural missteps because he acted pro se in significant parts of the trial.
3. Whether allowing Williams to conduct much of his defense deprived him of a fair and impartial trial, including a claim functionally resembling ineffective assistance based on his own performance.

## Decision

- The conviction and sentence were affirmed.
- No reversible error was shown from the extraneous-offense reference because the objection was general and untimely, much of the testimony was elicited by Williams, the objection that was made was sustained, and no further relief was requested.
- The court rejected any claim that pro se status entitled Williams to special procedural treatment.
- The court held Williams could not complain on appeal that the quality of his self-directed defense denied him a fair trial.

## Legal Principles

- Error is not preserved for appellate review without a timely objection stating specific grounds and a request for appropriate relief when necessary.
- When an objection is sustained and the party seeks no further relief (such as an instruction to disregard or mistrial), nothing is preserved for review on that complaint.
- A defendant who chooses self-representation remains bound by rules of procedure and substantive law; self-representation is not an exemption from courtroom rules.
- A defendant who substantially represents himself cannot obtain appellate relief by characterizing deficiencies in his own chosen advocacy as denial of a fair trial.

## Conclusion

The court affirmed the robbery-by-firearm conviction because the extraneous-offense complaint was not preserved and because a defendant who elects to represent himself must comply with ordinary procedural requirements and cannot later attack the trial’s fairness based on shortcomings in his own self-representation.


Williams v. State, 549 S.W.2d 183 (Tex. Crim. App. 1977)