Dorothy Williams - Cook County State's Attorney

Dorothy Williams - Cook County State's Attorney





DOCKET NO. __________

vs ) INMATE NO. B21483









Lori G. Levin

David A. Stoioff

Celeste Stewart-Stack



The People of the State of Illinois strenuously oppose petitioner Dorothy

Williams’ request that her death sentence be commuted and further request that the

Prisoner Review Board of the State of Illinois grant a full and complete hearing in

opposition to executive clemency. A full hearing will demonstrate that Williams is a

serial murderer of the elderly who has repeatedly and maliciously sought out the frailest

victims, robbed them of their possessions, and cruelly murdered them if they had the

temerity to resist her. Williams’ legacy of horror and heartache is rooted in her discovery

of senior citizens’ housing projects, for located in these buildings Williams accumulated

and cultivated an endless source of helpless victims.

These havens for the elderly became Williams’ hunting grounds. Using various

ruses to gain access to the seniors, Williams used her cunning to move freely through the

buildings in search of quick cash and easy prey. As her crimes mounted and the residents

became more fearful and wary, Williams simply became more cunning, ruthless and

brutally violent. Whether posing as a worker, or simply asking a kind-hearted soul for a

glass of water, Williams entered homes and ended lives, simply because she wanted a

few bucks.

For pocket money, Williams beat and stabbed her three murder victims. Despite

their frailty these people fought hard for their lives and died slow, painful and, as a result,

chillingly horrific deaths. It is shameful that these victims lived long and fruitful lives


only to die during every person’s worst nightmare: a home invasion by a brutal stranger.

These helpless seniors, frail with age and medical disabilities, opened their doors to

terrifying deaths, inflicted by a worthless criminal who has no place in civilized society.

Williams is a street cunning, brutal murderer convicted with overwhelming

physical, forensic, and testimonial evidence. Williams gave three court-reported

confessions to three separate murders of senior citizens. She has never claimed actual

innocence. Through extended fitness hearings and expert evaluations it has been

demonstrated that she attempted to translate her street smarts to forensic psychiatry and

failed miserably. These hearings exposed her as a manipulative malingerer, still trying to

avoid responsibility for her heinous and callous acts. As set out below, Williams was

convicted by overwhelming evidence and sentenced due to overwhelming aggravation.

To even consider commuting her sentence would be the ultimate travesty of justice by

violating these elderly victims’ dignity yet again

On April 18, 1991, the Honorable Judge Shelvin Singer sentenced Dorothy

Williams to death in case No. 89CR-20869, for the first-degree strangulation murder and

robbery of 97-year-old Mary Harris. As the Illinois Supreme Court unanimously stated,

“the evidence of guilt marshaled by the State against the defendant was overwhelming.”

People v. Williams, 164 Ill.2d 1, 27, 645 N.E.2d 844, 853 (1994). Her fingerprints were

found at the scene. The proceeds of the robbery were found at her home, there was a

witness placing her at the scene. Moreover, the defendant confessed before a courtreporter

to the murder of Mary Harris.

After the defendant was sentenced to death she plead guilty to three other cases

where she victimized frail senior citizens. She was sentenced to natural life in 89CR-


20870 and 89CR-20871, the felony murders of seniors Lonnie Laws and Caesar Zuell.

The defendant was also sentenced to 7 years in the penitentiary for the robbery of wheelchair

bound Jasper Irving. The evidence in all of these cases showed that the defendant

preyed on the weak, feeble and elderly in their own homes.

Dorothy Williams’ conviction and sentence were unanimously affirmed by the

Illinois Supreme Court in 164 Ill.2d 1 (1994). A post-conviction petition where she

alleged a myriad of mental health issues that she was denied by Judge Shelvin Singer on

August 20, 1999. At that time Judge Singer found that “there was overwhelming

competent evidence from the record of the trial court proceedings which reveals

convincingly that petitioner was not illiterate and did not have impairment of her

intellect.” The testimony adduced at this lengthy, protracted hearing lasted several days

and consists of hundreds of pages of transcript. A copy of Judge Singer’s fifty-page

ruling is appended to this response. The Illinois Supreme Court recently found that Judge

Singer should have addressed the issues of fitness for post-conviction proceedings and

the allegations within the post-conviction petition separately and has remanded the case

for a hearing on the merits of the post-conviction petition. The Court did not rule on the

merits or lack thereof of defendant’s claims. People v. Williams, __ Ill.2d__, 2002 Ill.

Lexis 340 (2002).

There exists a voluminous amount of evidence establishing Dorothy Williams

systematically robbed and killed seniors on the South Side of Chicago over a three to

four year period. She also introduced her daughter Cherika Williams to a senior, who

Cherika in turn robbed, following defendant’s death sentence. Dorothy Williams was

clinically and judicially found to be a malingerer, or faker, on the issue of her alleged


mental disability. Notwithstanding the above, the defendant is asking for executive

clemency claiming that she is mentally retarded.

The People vehemently oppose this request.

Facts of the Case

On July 25, 1989, 97-year-old Mary Harris spent five hours of her last day on earth

with her daughter Marian at Mary’s apartment at 4030 South Lake Park in Chicago. Mary

had lived in apartment 1204 of the Chicago Housing Authority Senior Building since the

late 1960's or early 1970's. When Marian left her mother at 2:30 p.m., Mary Harris was in

good health and wore a pink scarf around her head.

At 8 p.m., elderly friends of the victim found her door ajar. She was discovered

dead, with her kerchief around her neck. The police were summoned and her daughter was


Detectives Patrick McDonald and Thomas Grady went to the victim's apartment

and discovered no sign of forced entry. They observed Mary Harris lying on her bed. Both

of Ms. Harris' eyes were blackened and a pink scarf was knotted around her neck. Dresser

drawers were open and in disarray, as was her closet. Evidence technicians found

fingerprint impressions on five items that were sent to the crime laboratory.

When Marian Harris entered her mother's apartment that night, she too saw that

it had been ransacked. A Realistic Clarinet Sixteen, a small stereo, was missing as well as

a small cardboard box and a lightweight sheer bedspread. Marian Harris identified the

stereo at the police station after it had been recovered from defendant's apartment.

Seventy-one-year old Hubert Carmichael reported to the police that at 6:30 p.m.,

while he was in the day room on the first floor of 4030 S. Lake Park, he saw the defendant

leaving the building alone carrying a box large enough to hold the missing stereo set. He

had seen the defendant many times before and knew she had no legitimate reason to be in


the senior citizens building, she did not live there, had no relatives there, and did not work


It was Mr. Carmichael who helped the police solve Mary Harris’ murder. On

September 6, 1989, he saw the defendant, who had died her hair red and was wearing

glasses, with another woman, walking away from the corner bus stop. Mr. Carmichael

excitedly pointed defendant out to Officer Betty Woods. He told her what he had seen the

night of the murder and that he had also seen at another time the defendant choke another

elderly resident of the building.

Officer Woods, a senior citizens officer for the Chicago Police Department,

approached the two women. Officer Woods spoke with defendant and her companion.

Defendant lied to Officer Woods, saying that her name was "Deborah" Williams. Officer

Woods transported the two to the Area One Detective Division.

The defendant continued to claim she was Deborah Williams to the detectives.

After being advised of her rights, she initially stated she had not been in the 4030 Lake

Park building in years and that she did not know the victim.

Following this conversation, defendant signed a consent to search form. The

officers went to defendant's apartment and recovered a Realistic Clarinet Number Sixteen

stereo with two speakers. As the evidence against her mounted, the defendant began to

change her story bit by bit. When confronted with Mary Harris’ stereo, Dorothy Williams

admitted it belonged to her. Defendant stated that she had purchased the stolen stereo

approximately one month earlier from an unknown male black. Defendant could not

estimate the person’s age, weight, height or complexion. After this conversation an

evidence technician was called to take defendant's fingerprints.

The defendant then admitted that she previously gone to 4030 S. Lake Park, but

stated that she had never been on the victim’s floor. Once again she claimed she could not

describe the person from whom she bought the stereo.


After speaking with Assistant State’s Attorney Thomas Bilyk, Dorothy

Williams, using her true name, gave a handwritten statement, which she read and signed in

three places. Defendant stated that she was in the victim's building on the evening of the

murder to visit her friend "R.L." She met Clyde in the elevator and agreed to buy a stereo

from him. They went to the twelfth floor and Clyde opened the victim's door with a key.

The victim was "already moaning." Clyde went in and choked the victim with both hands.

When he finished choking the victim, defendant gave Clyde twenty dollars and lifted the

stereo set off of a dresser. Defendant and Clyde left the building together, Clyde carried

the stereo set out of the building. They walked together to defendant's apartment.

When a detective confronted her with the fact that Hubert Carmichael had seen

her leave the building alone carrying a box, the defendant changed her story once again. In

this final version, which was subsequently witnessed by Assistant State’s Attorney Michael

Jacobs and transcribed by a court reporter, the defendant stated that she had gone to the

victim's apartment looking for money to buy heroin. Defendant knocked on Mary Harris'

door and was admitted by Ms. Harris. The two had a short conversation. Ms. Harris gave

defendant two dollars to go buy her some milk. When Ms. Harris turned, defendant

wrapped her arms around the victim's waist, pulled her tight and the victim started

screaming. To silence her, the defendant took the "little rag" that Ms. Harris was wearing

on her head and pulled it tight into the victim's mouth. The struggle continued and Ms.

Harris scratched at defendant. The "rag" came down around Ms. Harris' neck and

defendant tightened it.

Ms. Harris lost consciousness and defendant dragged the victim's

body into the bedroom. Ms. Harris' body was cold to the touch. Defendant took the stereo

set and left the apartment.

After the statement was typed, the defendant read the first page of the statement

out loud, initialed each page and signed the final page of her statement.

Additionally, an expert determined that the defendant’s fingerprints had been

found on two items in Mary Harris’s apartment, a gift box and a business card.


Dr. Robert J. Stein, the Chief Medical Examiner of Cook County, performed

Mary Harris’ autopsy. Dr. Stein observed a "ligature," a pink handkerchief that was

knotted tightly around Ms. Harris' neck. Dr. Stein removed the handkerchief and saw an

abrasion on Ms. Harris' neck. The victim also suffered two black eyes, caused by separate

blows, and small hemorrhages in the whites of the eyes that were consistent with


His internal examination showed a hemorrhage to the neck and a hemorrhage to

the 'strap' muscles.

Her hyoid bone, which sits above and behind the adam's apple, was

fractured. Dr. Stein determined that seventeen pounds of pressure per square inch must

have been exerted to fracture the hyoid bone. Dr. Stein's expert opinion was that Mary

Harris died from ligature strangulation.

The defense offered no evidence at trial. Both sides presented closing arguments

and the jury was instructed on the applicable law. The jury found defendant guilty of

murder and robbery.

Death Penalty Hearing

The defendant waived a jury for purpose of the sentencing hearing. After the

first phase of the hearing was completed, Judge Singer concluded that the killing of Mary

Harris was executed during the completion of a robbery and found Dorothy Williams

eligible for the death penalty.

During the second phase of the death penalty hearing, extensive evidence was

presented showing how the defendant preyed on the elderly. As the Supreme Court noted,

“The evidence indicated in order to gain entrance to the apartments of many of these

elderly persons, as well as the apartments of still others, defendant used various ruses,

including the pretense that the resident knew or was related to her and the deception that


the defendant had come to aid the resident. The evidence indicated that defendant was often

physically abusive of these elderly persons whom she robbed.” 164 Ill.2d at 25.

Testimony was given concerning the two felony murders, 89CR-20870 and

89CR-20871, of senior citizens Lonnie Laws and Caesar Zuell which the defendant

subsequently plead guilty to and was sentenced to natural life by the Honorable Judge

James Heyda. The defendant has never challenged the validity of those convictions or


With respect to the murder of 79-year-old Lonnie Laws, on December 5, 1987 a

police officer was dispatched to 4218 South Cottage Grove, apartment 710 and found

Lonnie Laws motionless on his apartment floor. Two articles of clothing were wrapped in

a gag-like fashion around Mr. Laws face and a belt was wrapped tightly by around his

neck. As in the case of Mary Harris, this apartment was in disarray, the closet was

rummaged through and clothes were thrown on the floor. There was no sign of forced

entry. A wallet was opened on the bed, drawers were open and the contents were strewn

about the room.

Due to the similarities between the two murders, the defendant was questioned

regarding the murder of Lonnie Laws while in custody for Mary Harris’ murder. The

defendant gave another court-reported confession to Assistant State’s Attorney Jacobs.

Defendant stated that on the date of the murder she had sex with Mr. Laws, who was

intoxicated and "wild.” When defendant asked for money, Mr. Laws told defendant she

would have to come back for it. Defendant went through Mr. Laws' drawers when he cut

defendant with a knife. Defendant got angry and grabbed Mr. Laws.

According to

defendant, she gagged him with a belt that was hanging around his neck and asked for her

money. When Mr. Laws did not give defendant the money, defendant tightened the belt

around his neck and pushed Mr. Laws down. Defendant took the money from Mr. Laws'

robe and left.


The parties agreed that the defendant’s fingerprint was recovered from the

exterior door of Mr. Laws' apartment. The parties also stipulated that the autopsy revealed

Mr. Laws was five feet five inches tall and weighed 94 pounds. Mr. Laws suffered

hemorrhaging in both eyes and abrasions to his face and nose. Mr. Laws was gagged with

a pajama top that was tied in the back of the neck. Around Mr. Laws' neck was a belt.

Between Mr. Laws' eyebrows were multiple, irregular areas of abrasion and bruising.

Internal examination revealed multiple areas of hemorrhaging in the neck, throat,

esophagus and tongue and a fracture of the thyroid cartilage. The autopsy determined that

Lonnie Laws died of ligature strangulation. His blood alcohol level was well below the

legal definition of intoxication.

Concerning the murder of Caesar Zuell, on December 6, 1988 another officer

was summoned to apartment 813 at the senior building at 740 East 43rd Street. Upon

entering the apartment, the officer observed the decomposed body. The fire department

was called, and air tanks were requested because of the unbearable stench emanating from

the apartment.

The parties agreed to the testimony that an evidence technician found a latent

fingerprint impression from a whiskey bottle in Caesar Zuell's apartment and sent it to the

crime lab. The parties also stipulated that an expert fingerprint examiner, found the

defendant's palmprint on that bottle.

Both sides also agreed to the results of Caesar Zuell’s autopsy. It showed

Caesar Zuell was five foot, seven inches, weighed 120 pounds and was sixty-four years old.

Mr. Zuell's body exhibited skin slippage and discoloration indicating decomposition. Mr.

Zuell died from three stabs wounds to the chest and a lacerated lung.

Assistant State's Attorney Gabriel DeMatteo testified he took a court-reported

statement from the defendant on September 8, 1989. The defendant told him in December

of 1988 she got a call from Caesar Zuell asking defendant to have sex with him for fifty

dollars. After purchasing a pint of whiskey, she went to Mr. Zuell's. Mr. Zuell did not


want to pay defendant, so she wrestled with him trying to go into his pockets. Mr. Zuell

told defendant to leave his apartment brandishing a pocket-type knife. Defendant grabbed

Mr. Zuell by the wrist and pushed the knife into his chest. After this struggle, defendant

reached into Mr. Zuell's pocket, took eighty seven dollars and left. She claimed Mr. Zuell

was still standing when she took the money.

During the death penalty hearing, there was additional evidence concerning the

defendant’s victimization of the elderly. Seventy-two year old Jasper Irving was wheeled

into the courtroom. He testified that he suffered from cancer of the vocal chords and had

been using a walker for fifteen or twenty years. On January 11, 1986, Mr. Irving was living

at the senior citizen’s building at 4949 South Cottage Grove. On that day, the defendant,

who Mr. Irving had seen in the building before, knocked on Mr. Irving's door. When the

defendant stated she wanted some beer, Mr. Irving put two dollars on the table. The

defendant stated it was not enough, grabbed the money that Mr. Irving was holding in his

hand and the two dollars off the table and fled. After defendant left, Mr. Irving called some

former neighbors who were familiar with defendant who told Mr. Irving defendant's name.

Mr. Irving then called the police. One week later Mr. Irving identified the defendant for

the police.

Defendant was arrested, released on bond and never appeared in court to answer

these charges. On April 4, 1989, Mr. Irving was in his apartment at 4949 South Cottage

Grove when someone knocked on his door. The person outside Mr. Irving's door told him

there was a gas leak. Mr. Irving cracked open the door and saw defendant. She forced her

way into his apartment, knocking him to the floor. Defendant beat him in the head with a

stick and Mr. Irving fell backwards. Defendant then put her foot in the victim's face, got a

dishtowel and tied it around Mr. Irving's throat. Defendant then tightened the towel and

dragged him to the front of the apartment and said, "I don't know what I'm going to do with

you." Mr. Irving told defendant where he had two hundred and sixty dollars hidden and

she released him. Defendant took the money and Mr. Irving's key and left the apartment.


Mr. Irving called the police and identified her from a group of photographs. Two

years later defendant was apprehended and Mr. Irving went to court and identified

defendant. Mr. Irving testified that his skull was fractured as the result of the beating he

received from defendant. At the time of her arrest for Mary Harris’ murder, defendant had

an outstanding bond forfeiture warrant for this second robbery of Mr. Irving. Following

defendant’s sentence of death, she plead guilty to that robbery in Case No. 89CR-3376 and

was sentenced to 7 years in the penitentiary by Judge Heyda. Once again, defendant is not

challenging this conviction or sentence.

The People also presented evidence that the defendant had robbed three other

seniors in Mary Harris’ building or in surrounding senior buildings, Frederick Adamson on

July 4, 1989; Clyde Simmons on July 1, 1989, and Martha Foster on April 4, 1989. The

defendant’s July 4, 1989 robbery of Adamson was the third time she had victimized him.

During the first robbery of Adamson, she had squeezed his tongue and pulled it. During the

Simmons robbery, she had twisted his genitals and threatened to pull off his penis if he did

not give her money.

On August 2, 1989, a mere eight days after she killed Mary Harris, the defendant

was arrested for trespassing in the senior citizen building at 400 East 41 st Street. In this case

her attempt to enter a senior’s apartment by ruse was thwarted. The defendant had already

dyed her hair red claimed that her identity was her deceased sister Peggy Williams when

she was arrested and questioned by the police.

Additional evidence showed that in October of 1973, the defendant hit Emma

Lipsey with a 18 square inch wooden milk crate, knocking out two of her lower teeth. On

May 30, 1973, defendant kicked and stuck a police officer 10 to 12 times in the face and

chest after he arrested her for creating a disturbance. Defendant was convicted and fined for

resisting arrest. On March 10, 1975, defendant was convicted of delivery and possession of

marijuana and was sentenced to 18 months misdemeanor probation and fined $200. While


defendant was incarcerated pending her trial for Mary Harris’ murder, she verbally abused

and threatened a female correctional officer.

In mitigation, the defendant presented testimony that while pending trial, her

only disciplinary violation was the November 23, 1989 offense. Defendant’s mother, Annie

Pearl Williams testified that the defendant’s deceased father’s contact with her had been

limited essentially to “writing.” Annie Pearl Williams testified that the defendant had

attended school until she became pregnant with Cherika at 15. At no time did Annie Pearl

Williams testify that the defendant was unable to read this correspondence or that she was

of limited intelligence. Annie Pearl Williams testified that at the time of the hearing

defendant’s daughter Cherika was 22 years old and her son Terrance was 20. Cherika

testified that she had been raised by her mother and had a normal upbringing. (As

previously noted, subsequent to the defendant’s sentence of death, Cherika Williams plead

guilty to the July 3, 1992 aggravated battery to a senior citizen of 80-year-old Nathaniel

Crenshaw in case 92CR-17216. In her statement to the police, Cherika stated that she had

been introduced to Crenshaw by her mother and that she was attempting to take money

from him when she cut him with a knife (see appendix).

The defense presented no other evidence in mitigation. After both sides

presented arguments, Judge Singer found that no mitigating factors existed sufficient to

preclude the sentence of death.

Petitioner’s Allegations

Petitioner claims that her death sentence should be commuted in light of Atkins v.

Virginia, 122 S. Ct. 2242 (2002), because she is allegedly mentally retarded. Although

the court in Atkins noted that mental retardation is characterized as having a significantly

sub-average general intellectual functioning and significant limitations in adaptive


functioning in at least two skill areas with the onset prior to age 18 (122 S.Ct. at 2245

n.3), the Court expressly stated that it was not adopting a definition of mental retardation

and left it to the various states to adopt a definition of mental retardation and delineate

procedures for determining whether or not a particular defendant is mentally retarded. Id.

at 2249-50.

No case, by any standard, for mental retardation has been established regarding

the defendant. To the contrary, the testimony and rulings to date have portrayed the

defendant as a highly, skilled and highly manipulative person. The People have detailed

the facts of the defendant’s crimes that were the basis of clinical psychologist Edward

Blumstein’s findings that “there was premeditation involved, that she was rather

deceptive, wily ruthless” in her victimization of the elderly.

Dr. Blumstein, further testified that defendant’s IQ tests were all over the board,

ranging from 59-73. He characterized her as a malingerer, a faker. Dr. Blumstein,

testified that a number of the defendant’s IQ test scores were in the normal, although low

normal range. It was his expert opinion that the below normal scores were a result of the

defendant faking her condition. Specifically, Dr. Blumstein testified

“(T)his is an individual who is attempting to portray her intellectual functioning at a

much lower level that it really is, but at the same time that she’s doing that is unable to

actually recall exactly how she performed the time before. So you’re going to have

fluctuations that are occurring way beyond chance. In other words, if this were an

individual who were truly brain damaged (defendant claimed in her post-conviction

petition that her alleged mental deficiencies were caused by an accident which resulted

in brain damage. She has been unable to substantiate these allegations.), you pretty much


see a flat line. You know, you’d get two, three, possibly four point discrepancies. But not

ten points…(S)he’s malingering.”

Perhaps even more telling both Dr. Blumstein and Dr. Mathew Markos, a

forensic psychiatrist, testified that the defendant was able to manipulate them when they

first evaluated her in 1995 to ascertain her fitness for post-conviction petition and

retroactive fitness for trial issues. Defendant clearly has the intelligence to initially con

both these doctors before they reviewed her voluminous records and retested her in detail.

Dr. Mathew Markos, director of Cook County Forensic Clinical Services, testified

that when he first examined defendant in 1995, he found that she was not fit for

post-conviction proceedings and that he could not render an opinion on whether she had

been fit at the time of trial. Dr. Markos explained that, in 1995, he had accepted

defendant’s "self-report" of severe head injury and that he gave defendant the "benefit of

the doubt" based upon her presentation and complaints of memory loss. Also in 1995,

Dr. Blumstein had also evaluated her and found her unfit.

In 1997, Dr. Markos reexamined defendant after reviewing extensive police reports

concerning all three murders, court-reported statements, the pre-sentence investigation,

Dr. Blumstein’s 1997 report [finding her fit], medical and psychiatric records from

Dwight correctional center, Dr. Lahmeyer’ s report, Dr. Lillie’s report, and transcripts of

the trial and sentencing hearing. Dr. Markos also had additional records from Cook

County Jail and Dr. Blumstein’s 1997 reevaluation concerning his observations and the

results of tests that he administered.

Dr. Markos also reviewed the findings of Dr. Lahmeyer and Dr. Lillie, both of whom

offered a clinical diagnosis of malingering. These doctors also concluded that defendant


was fit for post-conviction proceedings and fit for trial in 1991. Dr. Markos then

discussed the absence of any evidence of head injury. There were no medical records

supporting the injury, there was no consistent age given for the incident allegedly

resulting in such injury. After reviewing all the documents and reports, Dr. Markos

performed a clinical examination of petitioner. Defendant was calm and cooperative,

maintaining good eye contact. Defendant was not disorganized, did not have abnormal

thought behavior. Defendant did not suffer from delusions, hallucinations, nor was she


Defendant, however, did report serious memory problems for "just about

everything." She did not know what she was charged with, her date of birth, or how old

her two grown children were. Yet, she could recall being struck by a car and that she

went to a hospital. She also was able to give details of treatment at Dwight penitentiary,

including the names and doses of medications that she was prescribed. Defendant further

stated that when she was transferred from Dwight to Cook County Jail, one medication

was substituted for another.

Dr. Markos noted that it was unusual that defendant did not know basic facts like

what day it was, yet could recall "precise information regarding her head injury and

psychiatric treatment. This alone, created a strong suspicion of malingering, or faking.

Dr. Markos stated that it was strange from a clinical standpoint that an "individual who

had no memory for basic personal details was able to spontaneously color a picture of

psychiatric sequela secondary to head injury which was not established in the first place."

Dr. Markos noted that the head injury was never reported to authorities or examiners at

Dwight and remained unreported until 1995. There was no indication "whatsoever that


any head injury took place which was documented by proper authority." Moreover, an

MRI, EKG and CAT-scan showed no evidence of hemorrhage, hematoma or lesions to

the brain.

Dr. Markos further stated that the police reports illustrated defendant was

purposeful, very organized, and goal directed in committing her crimes and during the

interrogation. The psychiatrist further found that there was no evidence of any cognitive

deficit or organic brain damage and defendant was malingering or faking.

Dr. Markos explained the discrepancy between his conclusion in 1995 and in 1997

stating: "back in 1995 based on the information that was made available to me...I

rendered an opinion. But it so happened that Miss Williams was malingering. And when

I reexamined her in 1997, the data was overwhelming. The clinical information and

findings clearly indicated a diagnosis of malingering and led me to make a finding of


Dr. Blumstein also testified that in 1995, he had no police reports, transcripts, or

court-reported statements and relied on defendant’s rendition of her mental capabilities.

After reading all these materials in 1997, he was able to develop relevant questions based

upon the facts and compare them with petitioner’s responses. He was also better able to

test petitioner. The records as well as her responses demonstrated the defendant’s


Although his ruling on her post-conviction petition was overturned on other

grounds, Judge Shelvin Singer ruled on August 20, 1999 that “petitioner had a basic

formal education, was able to read; and, in addition, had a crafty intelligence above that

of a normal person’s.”


Judge Singer’s observations were consistent with the Illinois Supreme Court’s

findings that the defendant used various ruses to gain entrance to the apartments of her

elderly victims. 164 Ill.2d at 33. This included telling one victim there was a gas leak in

the building. The defendant’s claim of mental retardation is also belied by her various

acts of deception and lies to escape responsibility for her crimes. For instance, following

her murder of Mary Harris, the defendant dyed her hair red, and gave multiple,

conflicting versions of her activities. She lied to the police about her real name, and

denied both being in the victim’s building, and knowing the victim.

In sentencing defendant to death on April 18, 1991, Judge Singer made the

following findings: “I do believe that Mary Harris was brutally beaten before she was

killed, indeed beaten around the head, the eyes, the face….Furthermore, I do believe that

the defendant developed and executed a scheme to prey on the elderly and the infirmed,

to rob these people, these people who could least afford it, and these people who are most

vulnerable. They are obviously easy victims because they are elderly and infirmed, and

they usually live alone, extreme difficulty getting to could, should the defendant be

arrested, and once in court, because of the variety of physical conditions and the like, as

witnessed, they are not as articulate as would other people bee—or other people be as

witnesses. Miss Williams took terrible advantage of these people in a most cruel—in a

most cruel way.” ( see appendix. pp. 102, 104-5) These findings support the fact that

defendant victimized seniors in a cruel, heartless, systematic manner that a truly

mentally retarded person would be unable to do.

To bolster her claims, the defendant has attached an unsworn, unsigned,

“affidavit” made allegedly by her brother John claiming that petitioner cannot read and


that she did not attend high school. He further claims that the defendant dropped out of

school at age 14. This individual did not testify at the death penalty hearing. His

“affidavit” directly refutes his own mother’s testimony stating that defendant dropped

out of high school at age 15. It further contradicts the information defendant gave to the

probation officer preparing her pre-sentence report wherein she stated that she dropped

out of Forrestville High School at age 15. Moreover, the school records provided to this

board are obviously incomplete in that since defendant was born on December 24, 1954,

she was 12 years of age during the last grading period reflected in September 1967, not

age 14. Additionally, page 33 of the defendant’s appendix indicates that the defendant’s

total IQ score was 73, clearly not within the mentally retarded range. The records

provided to the board do not support defendant’s contentions.

Defendant’s disciplinary record in IDOC reflects conduct which is both defiant

and hostile. She has managed to come into possession of drugs and other contraband; has

violated rules, and has intimidated and threatened others. (see appendix). It is clear that

the defendant has no desire to comport her behavior within the rule of law.


Dorothy Williams purposely sought out the frailest and most defenseless seniors

and preyed upon them in their own homes. She robbed and strangled Mary Harris to

death, she robbed and strangled Lonnie Laws to death, she robbed and stabbed Caesar

Zuell to death and she terrorized and stole from Jasper Irving, Frederick Adamson, Clyde

Simmons and Martha Foster. Just eight days after she strangled the life out of Mary

Harris, she was caught with her appearance altered giving a false name at yet another


senior citizen building. Her actions were methodical and cruel. It is also significant to

note that the defendant has yet to express responsibility or remorse for her crimes or that

“mental retardation” has impaired her from doing so. There simply is no justification or

reason to grant this unsigned baseless clemency petition, and the well-reasoned decision

imposing the sentence of death should not be compromised.


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