## Facts

- After finishing work at an Indianapolis nightclub in the early morning, the complaining witness asked Adrian Williams and Antoine Edmondson for a ride home.
- Instead of driving her home, Williams drove to an alley; when the witness tried to leave, Edmondson pulled her into the back seat.
- Williams drove to a park and stopped in a dark area; the men demanded simultaneous sexual acts.
- Edmondson displayed a handgun and removed parts of the witness’s clothing.
- The witness seized the gun, escaped, fired while fleeing, and shot Edmondson in the jaw.
- Williams was charged and, after a jury trial, convicted of attempted criminal deviate conduct (Class A felony) and criminal confinement (Class B felony).
- The defense theory was consent in exchange for drugs; Williams sought to admit evidence of the witness’s prior drug use and alleged prior prostitution/sexual conduct, which the trial court excluded under relevance principles and Indiana Evidence Rule 412.

## Issues

1. Whether the trial court erred by excluding evidence of the victim’s prior drug use.
2. Whether the trial court erred by excluding evidence of the victim’s past sexual conduct under Indiana Evidence Rule 412.
3. Whether the trial court erred in denying Williams’s motion for continuance.
4. Whether prosecutorial misconduct warranted reversal.
5. Whether the evidence was sufficient to support convictions for attempted criminal deviate conduct and criminal confinement.

## Decision

- Transfer was granted; the intermediate appellate decision was vacated; the convictions were reinstated.
- The trial court acted within its discretion in excluding evidence of prior drug use as irrelevant and as improper character/propensity proof.
- The trial court properly excluded evidence of alleged prior prostitution/sexual conduct under Evidence Rule 412; the proffer did not fit a recognized exception.
- Denial of a continuance was not an abuse of discretion because Williams failed to show concrete prejudice.
- Alleged prosecutorial misconduct did not place Williams in grave peril warranting reversal.
- The evidence, viewed favorably to the verdict, was sufficient for a reasonable jury to find guilt beyond a reasonable doubt.

## Legal Principles

- Evidence of a witness’s prior drug use is generally inadmissible absent a specific, non-speculative showing that it affected perception, memory, credibility, or bias in the case; otherwise it is irrelevant and may be excluded under Rules 401–403.
- Indiana Evidence Rule 412 bars evidence of a sexual-assault complainant’s past sexual conduct offered to prove consent or credibility through propensity reasoning; admissibility requires a clearly applicable Rule 412 exception.
- Trial courts have broad discretion over evidentiary rulings and continuances; reversal requires an abuse of discretion and a showing of prejudice affecting fundamental fairness.
- Prosecutorial misconduct warrants relief only if the conduct was improper and subjected the defendant to grave peril.
- On sufficiency review, an appellate court does not reweigh evidence or assess witness credibility and considers only evidence and reasonable inferences supporting the verdict.

## Conclusion

The Indiana Supreme Court reinstated Williams’s convictions, holding that the trial court properly excluded proffered drug-use and sexual-history evidence, committed no reversible error in denying a continuance or in addressing alleged prosecutorial misconduct, and that the record contained sufficient evidence to support the jury’s findings of attempted criminal deviate conduct and criminal confinement.


Williams v. State, 681 N.E.2d 195 (Ind. 1997)