Joshua Williams was originally convicted in 2019 of being a felon in possession of a firearm and sentenced to a mandatory minimum of 180 months followed by five years of supervised release. After a summary reversal and resentencing, he was placed on three years of supervised release with conditions prohibiting further crimes, drug use, and possession of dangerous weapons. In March 2025, his probation officer petitioned to revoke his release following a domestic altercation with his father, Jerry Williams. The government alleged Williams committed aggravated assault, possessed a deadly weapon, and used drugs. At the final revocation hearing, Williams admitted to drug use but contested the assault and weapon charges. The government introduced body camera footage, voicemails from the victim, a photo of a knife, and a signed affidavit from the victim, all of which Williams's counsel accepted without objection.
The Eleventh Circuit addressed two primary challenges: the admission of hearsay evidence and the sufficiency of the evidence supporting the violations. Regarding the hearsay, the court applied the doctrine of invited error. Because Williams's counsel stated he had '[n]o objection' to the exhibits, the court held that Williams waived any right to argue that the district court failed to conduct the *United States v. Frazier* balancing test. The court noted that even if error occurred, it would be harmless because other properly admitted evidence, such as the unobjected-to affidavit and voicemails, independently proved the violations. On the sufficiency of the evidence, the court analyzed the elements of aggravated assault under Florida law, which requires an intentional threat creating a 'well-founded fear' of imminent violence. The court reasoned that a victim's fear can be inferred from circumstances that would induce fear in a reasonable person. The record showed Williams pulled a knife on his father and told him to 'come on,' which the court found sufficient to infer the required fear. Regarding the weapon possession, the court found the recovery of the knife in the yard where Williams was walking, combined with his statement to an officer that he would 'tell you yeah if you want to take me to jail,' supported the inference that he possessed and then discarded the weapon.
The judgment affirming the revocation of Williams's supervised release is final. Williams remains subject to a 24-month term of imprisonment. The decision reinforces that defense counsel must actively object to hearsay evidence in revocation hearings to preserve the right to challenge the admission under *Frazier*, as a failure to object constitutes a waiver under the invited error doctrine.