Bryant v. State
309 Ga. App. 649
Ga. Ct. App.2011Background
- Bryant was convicted of aggravated assault, criminal damage to property in the second degree, and battery.
- Victim, Bryant's ex-wife, and Bryant had been dating; after a heated argument Bryant followed the victim to his car and punched him through the car window.
- Bryant fired a handgun; the bullet missed the victim but damaged the car door frame, causing $573 in damage.
- Police recovered a spent shell casing; ballistics matched Bryant's handgun; Bryant initially denied involvement but later claimed self-defense and directed officers to the handgun.
- Witness testimony supported the events; the jury convicted Bryant after trial; Bryant challenged sufficiency of evidence and Batson voir dire challenges.
- Trial court denied the Batson challenge; appellate court affirmed, deferring to trial court findings on discriminatory intent and race-neutral explanations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Bryant contends evidence insufficient to convict. | State argues sufficient evidence from victim and ballistics. | Evidence sufficient to support conviction beyond reasonable doubt. |
| Batson challenge to peremptory strikes | State struck five of six African-American jurors; race-based prejudice alleged. | Proffered race-neutral explanations for strikes; trial court credited them. | No reversible error; trial court properly found explanations race-neutral and lacked discriminatory intent. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (Supreme Court, 1979) (sufficiency review; rational trier of fact determine guilt beyond reasonable doubt)
- Hampton v. State, 272 Ga. 284 (Georgia Supreme Court, 2000) (credibility and conflicts resolved by jury; defer to jury findings)
- Odim v. State, 228 Ga. App. 158 (Georgia Court of Appeals, 1997) (juror credibility and evidence assessment for appellate review)
- White v. State, 301 Ga. App. 837 (Georgia Court of Appeals, 2010) (Batson challenges; deference to trial court findings)
- McKenzie v. State, 294 Ga. App. 376 (Georgia Court of Appeals, 2008) (totality-of-the-circumstances analysis for discriminatory intent)
- Flanders v. State, 279 Ga. 35 (Georgia Supreme Court, 2005) (employment as social worker as race-neutral strike basis)
- Trice v. State, 266 Ga. 102 (Georgia Supreme Court, 1995) (lack of responsiveness as race-neutral strike basis)
- Lingo v. State, 263 Ga. 664 (Georgia Supreme Court, 1993) (difficulty in obtaining juror response as race-neutral)
- Alford v. State, 224 Ga. App. 451 (Georgia Court of Appeals, 1997) (prior negative involvement with law enforcement as race-neutral strike basis)