Blevins v. State
291 Ga. 814
| Ga. | 2012Background
- Blevins was convicted by a Richmond County jury of malice murder, armed robbery, arson in the first degree, and several traffic offenses.
- The evidence shows Blevins was seen in Jones’s parking lot with alcohol and later encountered Jones’s farm and residence.
- Jones was killed by blunt force, with a nearby bloodstained two-by-four and fence post found.
- Blevins went to an Augusta pawn shop and attempted to pawn Jones’s property, including a watch.
- A deputy stopped Blevins for DUI and found Jones’s watch, coins, and keys in his possession, with Jones’s blood on Blevins’s shirt.
- Blevins made an incriminating statement and could not provide a satisfactory exculpatory explanation; circumstantial evidence linked him to the crimes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to sustain convictions | Blevins contends insufficient evidence | State argues evidence excludes reasonable hypotheses | Yes; evidence excludes reasonable hypotheses and supports guilt |
Key Cases Cited
- Abston v. State, 291 Ga. 531 (Ga. 2012) (circumstantial-evidence linkage to crime)
- Phillips v. State, 287 Ga. 560 (Ga. 2010) (reasonable-hypothesis standard applies to circumstantial evidence)
- Weston v. State, 276 Ga. 680 (Ga. 2003) (proximity and timing of killing and fire supporting inference)
- Green v. State, 283 Ga. 126 (Ga. 2008) (circumstantial-evidence sufficiency in murder cases)
- Bryant v. State, 282 Ga. 631 (Ga. 2007) (context of reasonable inferences in evaluating evidence)
- Merritt v. State, 285 Ga. 778 (Ga. 2009) (requirement to exclude reasonable hypotheses)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for reviewing circumstantial evidence sufficiency)