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Boring v. State
289 Ga. 429
| Ga. | 2011
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Background

  • Appellant Courtney Boring was convicted of malice murder and firearm possession and sentenced to life plus five years.
  • The State sought to admit highly prejudicial character evidence from the victim’s daughter’s bedroom items linking to a 'gothic' lifestyle and alleged satanic influences.
  • The State's theory tied the murder to appellant avenging her mother's interference with her relationship with Linville; no direct nexus shown between the items and the crime.
  • Forensic evidence indicated the rifle found was the murder weapon, the autopsy deemed the death homicide, and the shooting occurred inside the home with no forced entry.
  • Investigators targeted appellant; other suspects were ruled out; timeline largely supported by cell phone records and witness statements.
  • The trial court admitted the contested evidence over objections, and the conviction was challenged on appeal as reversible error.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of the evidence Boring argues evidence sufficed to convict beyond reasonable doubt State contends evidence supports guilt beyond reasonable doubt Evidence sufficient to sustain verdict
Admissibility of character evidence linking to 'gothic/satanic' beliefs State claims evidence relevant to state of mind and motive Admission was prejudicial and not linked to the crime Admission reversible error; highly prejudicial without nexus to crime

Key Cases Cited

  • Wolfe v. State, 273 Ga. 670 (Ga. 2001) (relevance of evidence does not escape exclusion when highly prejudicial)
  • Lindsey v. State, 282 Ga. 447 (Ga. 2007) (harmless error standard for nonconstitutional error)
  • Sumlin v. State, 283 Ga. 264 (Ga. 2008) (prosecutor improper closing argument injecting new evidence)
  • Alexander v. State, 270 Ga. 346 (Ga. 1998) (prosecutor's description of defendant's alleged gang ties; reversible error where no evidence)
  • McIntyre v. State, 266 Ga. 7 (Ga. 1995) (evidence of satanic cult admissible when tied to motive or retaliation)
  • Dawson v. Delaware, 503 U.S. 159 (S. Ct. 1992) (evidence of association with disturbing group improper where no connection to crime)
Read the full case

Case Details

Case Name: Boring v. State
Court Name: Supreme Court of Georgia
Date Published: May 31, 2011
Citation: 289 Ga. 429
Docket Number: S11A0536
Court Abbreviation: Ga.