Bright v. State
292 Ga. 273
| Ga. | 2013Background
- Bright was convicted of malice murder and aggravated assault in DeKalb County for Jenkins's death on Oct. 30, 2008.
- Eyewitnesses testified Bright argued with Jenkins, produced a gun, and fired multiple times; Jenkins died from two gunshot wounds to the head.
- Bright claimed he left Smith’s house by mid-afternoon and did not witness the confrontation or possess a gun; his sister corroborated his evening absence.
- The jury deemed eyewitness credibility and surrounding evidence sufficient to convict beyond a reasonable doubt.
- Bright challenged both the sufficiency of the evidence and his trial counsel’s effectiveness; the trial court denied relief and the Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to convict | Bright argues the evidence doesn’t prove guilt beyond a reasonable doubt | State asserts a rational jury could find guilt from eyewitnesses and surrounding circumstances | Evidence sufficient for guilt beyond reasonable doubt |
| Ineffective assistance—jail evidence | Trial counsel should have objected to testimony that Bright was in jail as character evidence | Testimony about jail confinement does not place Bright’s character into evidence | Counsel's performance not deficient; no prejudice |
| Ineffective assistance—voir dire | Counsel failed to question jurors with personal connections to violent crime | Strategic decision not to perform individual voir dire was reasonable | No deficient performance or prejudice; trial strategy reasonable |
Key Cases Cited
- Hampton v. State, 272 Ga. 284 (2000) (credibility of witnesses and evidentiary weight reviewed on appeal)
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of evidence)
- Williams v. State, 242 Ga. 757 (1978) (jury may consider jail confinement not necessarily character evidence)
- Taylor v. State, 272 Ga. 559 (2000) (trial court decisions on objections and strategy presumed reasonable)
- Morgan v. State, 276 Ga. 72 (2003) (voir dire strategy can be a matter of trial strategy)
- Cade v. State, 289 Ga. 805 (2011) (lack of individual juror questioning not necessarily deficient performance)
- Suggs v. State, 272 Ga. 85 (2000) (standard for applying Strickland prejudice inquiry)