Iowa Supreme Court again affirms Williams’ murder conviction; rules against fair jury challenge

By Bob Steenson, bsteenson@charlescitypress.com

A man convicted in 2017 of a Charles City murder has again had his conviction affirmed by the Iowa Supreme Court, which has also now ruled that the man failed to prove that the jury selection process used for his trial was unconstitutional.

Antoine Williams of Charles City, now age 41, was convicted of second-degree murder for the June 30, 2017, shooting death in Charles City of Nathaniel Fleming, age 36, of Mason City.

Williams had been charged with first-degree murder, but the Floyd County jury found him not guilty of that charge and instead convicted him of second-degree murder. He was sentenced to up to 50 years in prison, with a requirement that he serve at least 35 years before being eligible for release.

Williams, who is Black, appealed his conviction and his sentence, making five arguments, including alleging a violation of his U.S. Constitutional Sixth Amendment right to trial by an impartial jury, because the jury that convicted him had no African-Americans on it, nor did it appear that there were any African-Americans on the list of potential jurors who could have been selected.

Williams’ attorneys argued that the method used to select jury pools in Floyd County under-represented the number of African-Americans in the community. Floyd County District Court Judge Rustin Davenport had rejected this argument during the original trial.

In 2019, the Iowa Supreme Court ruled against four of William’s appeal arguments, conditionally affirming his conviction, but sending the case back to Floyd County District Court with instructions to allow Williams to use new guidelines that had been established by the court to try to prove his jury had been unfairly selected.

In August 2020, a hearing was held in Floyd County District Court before the original case judge, Davenport. In January 2021, Davenport issued his ruling, a 35-page document filled with statistical analysis, saying Williams had again failed to prove that his jury pool had an unfair or unreasonable representation of a distinct group.

Williams appealed Davenport’s latest ruling, arguing that four jury management practices were the cause of the alleged underrepresentation: (1) failing to use more than the voter registration list to summon jurors for the pool, (2) failing to sufficiently enforce penalties for summoned jurors’ failures to appear, (3) failing to promote responsiveness by using an online summons and reminder system, and (4) failing to summon jurors using a randomized process.

The Iowa Supreme Court ruled that the practices cited by Williams were common “run of the mill” jury management practices that are within the state’s discretion and that the court had ruled could not be used to sustain a challenge under the Sixth Amendment.

The court also said Williams failed to recognize “that at the time of his trial Floyd County was already using not only the voter registration list but also the motor vehicle operator list and nonoperator identification list to construct the source list.”

The court said it found no error in its previous interpretation of federal case law “to bar Sixth Amendment challenges that allege systemic exclusion as a consequence of run-of-the-mill jury management practices.”

“In Williams I, we conditionally affirmed Williams’s conviction and remanded for a determination on his fair-cross-section challenge. We now affirm the district court’s holding on remand that Williams failed to prove a violation of his Sixth Amendment right to an impartial jury, and affirm his conviction,” the Iowa Supreme Court ruled.

The court issued a similar ruling affirming the conviction of Peter Veal, who had been convicted of two murders and attempted murder in Mason City at about the same time as the Williams case, and whose case had also been sent back to have jury selection reconsidered.