Bowman v. State, 306 Ga. 97

In May 2014, Michael DeWayne Bowman shot and killed off-duty Griffin Police Officer Kevin Jordan during an altercation at a Waffle House; Bowman also shot at bystanders and wounded Raymond Jordan, who returned fire. Surveillance video captured the incident.
A Spalding County grand jury indicted Bowman on multiple counts including malice murder, felony murder, aggravated assault on a peace officer and on Raymond Jordan, obstruction, and multiple firearm-possession enhancements; the State initially sought the death penalty but later withdrew that notice.
At trial Bowman pursued an insanity/dissociation defense based on PTSD and a traumatic brain injury from military service; defense experts testified he was in a dissociative state and reacted as if in combat.
The State and court-appointed experts disputed the defense experts, attributing Bowman’s conduct to voluntary action and long-term steroid use rather than PTSD or TBI.
A jury returned guilty-but-mentally-ill verdicts on Counts 1–6 and guilty on remaining counts; Bowman was sentenced to life without parole for malice murder plus consecutive terms for related offenses.
Bowman appealed, asserting insufficiency of the evidence as to intent and voluntariness, claiming he had shown insanity, and arguing Officer Jordan was not acting as a law-enforcement officer at the time (an argument rendered moot as those counts were vacated or merged).

Issue	Bowman’s Argument	State’s Argument	Held
Sufficiency of evidence to prove criminal intent	No direct proof of intent; actions were involuntary due to dissociation	Circumstantial evidence (statements, conduct, accurate shots into officer’s back, wild firing) and expert rebuttal supported intent	Affirmed: jury could infer criminal intent from circumstances and credibility findings
Voluntariness of actions	Defense experts: Bowman was in a dissociative state from PTSD/TBI; acts were not voluntary	State and court experts: actions were not caused by PTSD/TBI; evidence supported voluntariness	Affirmed: jury credited State and court experts and found acts voluntary
Insanity (not guilty by reason of insanity) burden	Bowman argued he proved insanity by preponderance based on expert testimony	State argued competing expert testimony defeated the insanity claim; defendant bears burden	Affirmed: jury not required to accept defense experts; verdict upheld absent overwhelming evidence of insanity
Whether Officer Jordan was acting as law-enforcement at time	Bowman contended Jordan was not acting as a peace officer so certain counts failed	State noted but those counts were vacated/merged for sentencing	Moot: issue did not affect outcome; claims concerning those counts are moot

Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence)
Fuss v. State, 271 Ga. 319 (jury may reject defense expert testimony; sufficiency to support guilty but mentally ill)
Buford v. State, 300 Ga. 121 (defendant bears burden to prove insanity by preponderance; review of competing expert testimony)
Alvelo v. State, 290 Ga. 609 (insanity burden and legal standards)
Boswell v. State, 275 Ga. 689 (jury verdict on insanity upheld absent overwhelming evidence)
Dixon v. State, 302 Ga. 691 (procedural sentencing/merger authorities cited by court)
Stephens v. State, 303 Ga. 530 (mootness of challenges to vacated or merged counts)