Beaudoin v. State
311 Ga. App. 91
Ga. Ct. App.2011Background
- Beaudoin was convicted after a jury trial of statutory rape as a lesser included offense of multiple indicted sex offenses against a 12-year-old victim.
- Beaudoin befriended the victim and engaged in sexual contact, including fondling, finger insertion, and sexual intercourse with the victim.
- The evidence supported the jury finding Beaudoin guilty beyond a reasonable doubt of the charged offenses.
- A prospective juror was not dismissed for cause despite concerns about bias related to the crime.
- Beaudoin challenged the admissibility of his statements to police and the polygraph examiner’s testimony, and sought a jury instruction on simple battery as a lesser included offense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Beaudoin argues evidence insufficient for guilty verdicts. | State contends evidence shows sexual contact with a minor. | Evidence sufficient to support verdicts beyond reasonable doubt. |
| Juror for-cause dismissal | Beaudoin claims the juror was biased and should have been dismissed. | Beaudoin contends the court abused discretion by not dismissing. | Court did not abuse discretion; juror could be impartial despite bias about the crime. |
| Jackson-Denno voluntariness | Statements to police were involuntary as condition of custody or coercion. | Statements were voluntary under totality of circumstances. | Statements found voluntary; admissible under Jackson-Denno. |
| Polygraph testimony admissibility | Polygraph examiner testimony about deception should be excluded. | Stipulation made polygraph results admissible; testimony proper. | Admissible due to express stipulation; no error in admitting examiner's testimony. |
| Lesser included offense - simple battery | Trial court should have charged simple battery as lesser included offense. | No evidence that simple battery was a lesser included offense of indicted crimes. | No error; simple battery not shown to be a lesser included offense. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard; rational trier of fact)
- McCoy v. State, 278 Ga.App. 492-493 (Ga. App. 2006) (standard for sufficiency review in Georgia)
- Brown v. State, 243 Ga.App. 632 (Ga. App. 2000) (juror impartiality and for-cause challenges)
- Pearce v. State, 300 Ga.App. 777 (Ga. App. 2009) (juror biases from crime type; impartiality allowed)
- Lockett v. State, 258 Ga.App. 178 (Ga. App. 2002) (child molestation victim as basis for juror suitability)
- Patterson v. State, 212 Ga.App. 257 (Ga. App. 1994) (polygraph admissibility when stipulation valid)