Alexander v. State
294 Ga. 345
Ga.2013Background
- Appellant Robert Alexander was convicted of two counts felony murder, aggravated battery, and cruelty to children, and sentenced to life without parole for felony murder.
- Diamone Wilson, a healthy two-year-old, was in appellant’s care while Daniels was at a doctor's appointment, then found unconscious with severe injuries.
- Medical findings included a five inch by six inch skull fracture, liver laceration, multiple fractures, possible cigarette burns, and patterned abdominal injury; death followed by head trauma.
- Appellant claimed Diamone had not fallen or been injured and that she seized or choked while eating; later he suggested a prior fall down stairs months earlier.
- The State’s case relied on circumstantial evidence showing Diamone was healthy in appellant’s care, incapacitated immediately by injuries, and that appellant was alone with her during the buildup of injuries.
- Defense challenged voir dire scope and trial comments, while the court addressed Daniels’ prior statements and the credibility of the witness under OCGA § 17-8-57.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | State argues evidence shows blunt force trauma caused death. | Alexander contends evidence fails to exclude other causes. | Evidence sufficient for reasonable jury to find guilt beyond reasonable doubt. |
| Scope of voir dire | State’s voir dire limited defense inquiry into bias. | Alexander claims trial court improperly restricted voir dire. | Voir dire scope sufficient under OCGA § 15-12-133; no abuse. |
| OCGA § 17-8-57 and trial judge's questioning of Daniels | Questioning violated 17-8-57 by implying credibility issues. | Questions served to clarify testimony, not to indicate guilt. | No violation; judge’s questions were objective and clarify testimony. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (sufficiency standard for challenging convictions)
- Zamora v. State, 291 Ga. 512 (Ga. 2012) (circumstantial evidence sufficiency framework)
- Carter v. State, 276 Ga. 322 (Ga. 2003) (standard for circumstantial-evidence cases)
- Ellington v. State, 292 Ga. 109 (Ga. 2012) (scope of voir dire and 'subject matter' guidance)
- Finley v. State, 286 Ga. 47 (Ga. 2009) (trial court comments to develop truth allowed)
- Curry v. State, 283 Ga. 99 (Ga. 2008) (trial court questioning not improper under 17-8-57)
- Sallie v. State, 276 Ga. 506 (Ga. 2003) (voir dire purpose and panel inquiry boundaries)