Avila v. State, 289 Ga. 409

Avila was convicted of malice murder and possession of a firearm during the commission of a crime related to the February 7, 2008 shooting of Antwan Cole.
Avila had harbored anger toward Cole over a break-in at Avila's father's home and argued with Cole at a driveway meeting after taking a revolver from his roommate without permission.
During the confrontation in Cole's pickup truck, Avila fired multiple shots, Cole was fatally wounded, and Avila was stabbed; Avila subsequently fled the scene and discarded the gun.
Initial police statements conflicted with Avila’s later accounts, and Avila’s statements evolved across statements, pre-trial hearings, and trial testimony.
The State introduced similar transaction evidence of Avila shooting Tiffany Marler a month earlier in Cobb County using the same weapon and giving false police accounts, arguing it showed a common plan or modus operandi.
The trial court issued a limiting instruction, and the jury ultimately rejected Avila’s self-defense justification defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supports sufficiency of the verdict	Avila asserts insufficient evidence for guilt beyond reasonable doubt.	Avila argues inconsistencies and self-defense negate guilt.	Evidence sufficient to uphold verdict.
Whether similar transaction evidence was admissible	State contends prior shooting shows common plan and material similarity.	Avila argues prior incident is not sufficiently similar or relevant.	Admission of similar transaction not an abuse of discretion.

Vega v. State, 285 Ga. 32 (2009) (credibility issues for jury; justification defense left to jury)
Whitehead v. State, 287 Ga. 242 (2010) (similar transaction admissibility; focus on similarities)
McNeil v. State, 284 Ga. 586 (2008) (jury determines credibility; self-defense limitations)
Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency of evidence standard; rational jury verdict)