Brown v. State
294 Ga. 677
| Ga. | 2014Background
- Brown was convicted of malice murder, aggravated assault, and giving false information to police for the December 24, 2010 axe killing of Charlotte Grant; Grant lived with Brown and her adult children in the same house.
- Brown and Grant were in a romantic relationship; Grant was still married to another man.
- An argument preceded the attack; Pride and Medley joined the confrontation; Medley pushed Brown but there was no contact between Grant and Brown.
- Brown retrieved an axe and swung at Grant and Medley, killing Grant with multiple axe wounds; an axe was left near a back-door area and blood was found on Brown’s clothing.
- After fleeing, Brown gave a false name and birth date to a police officer and later offered various accounts of how the weapon was obtained and who was responsible; a custodial interrogation followed.
- A motion to suppress Brown’s custodial statements based on Miranda/Denno challenges was denied by the trial court; Brown challenged the lack of explicit voluntary-wavier findings but the court did not remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the evidence sufficient to convict Brown beyond a reasonable doubt? | Brown | State argues sufficient evidence | Yes; evidence supports guilt (Jackson v. Virginia standard). |
| Was the suppression order for custodial statements infirm for not explicitly stating voluntariness? | Brown | Order lacks explicit voluntariness findings | No remand required; no evidence shown of involuntariness; findings preferred but not necessary here. |
| Should Brown have been given a voluntary manslaughter instruction as a lesser included offense? | Brown | No basis for provocation sufficient for voluntary manslaughter | No error; no substantial provocation showing required by OCGA 16-5-2 (a). |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for criminal evidence)
- Bryant v. State, 268 Ga. 664 (Ga. 1997) (recommendations for trial court findings in suppression rulings)
- Parker v. State, 255 Ga. 167 (Ga. 1985) (importance of proper findings in suppression orders)
- Colton v. State, 292 Ga. 509 (Ga. 2013) (clarifies remand considerations in suppression rulings)
- Merritt v. State, 292 Ga. 327 (Ga. 2013) (provocation and voluntary manslaughter standards)
- Davis v. State, 290 Ga. 421 (Ga. 2012) (admissibility and provocation context for manslaughter questions)
- Howard v. State, 288 Ga. 741 (Ga. 2011) (provocation and mandatory basis for involuntary manslaughter charge)
- Baugh v. State, 293 Ga. 52 (Ga. 2013) (voluntary manslaughter limitations in provocation analysis)