Buford v. State, 300 Ga. 121

On July 1, 2003, Norman Buford shot into a parked vehicle, killing Willie Archer and wounding Orantes Dishmond; Buford waived a jury and asserted an insanity defense.
Buford told investigators he heard voices telling him to "do it." He had a history of psychiatric treatment in the 1990s but had not been on psychotropic medication immediately before the shooting; after arrest, antipsychotics reduced his hallucinations.
Dr. Simon Sebastian (forensic examiner) diagnosed schizophrenia and testified Buford experienced auditory hallucinations and sometimes acted on voices, but was equivocal whether Buford knew right from wrong at the time of the shooting.
Dr. Deborah Gunnin (competency examiner) concluded Buford had symptoms of a mental disorder but could not, with reasonable psychological certainty, determine whether he could distinguish right from wrong or whether a delusional compulsion overmastered his will.
The trial court found Buford guilty but mentally ill on all counts after a bench trial; sentencing initially imposed life for both malice murder and felony murder, plus consecutive terms for aggravated assault and firearm possession.
On appeal the Court affirmed the guilty-but-mentally-ill verdict but vacated the duplicate life sentence for felony murder, directing that the felony-murder life sentence be vacated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred by not finding Buford not guilty by reason of insanity	State: Evidence was sufficient to support guilty-but-mentally-ill; insanity not proved by preponderance	Buford: Schizophrenia and expert testimony established legal insanity (couldn't distinguish right from wrong / delusional compulsion)	Court: Affirmed guilty-but-mentally-ill; Buford failed to prove insanity by a preponderance given equivocal expert opinions and other evidence
Whether prosecutor misstated facts and whether court relied on those misstatements	Buford: Prosecutor misstated medication history and court relied on it	State: Any misstatement was unpreserved; record supports finding Buford had history of not taking meds and avoiding treatment	Court: No reversible error; statements not preserved and overall record supports court's remarks
Proper legal standard for insanity proof	N/A (contextual)	N/A	Court applied Georgia law burden: defendant must prove insanity by preponderance; delusional compulsion requires a delusion that would justify the act
Sentencing: Whether imposing life for both malice and felony murder was proper	State imposed both life sentences	Buford challenged duplicate life sentences	Court: Vacated life sentence for felony murder (cannot sentence separately to life for both convictions)

Avelo v. State, 290 Ga. 609 (preponderance standard for insanity defense)
Fuss v. State, 271 Ga. 319 (trial court may reject expert testimony and consider conduct, demeanor, circumstances)
Jackson v. Virginia, 443 U.S. 307 (sufficiency of the evidence standard)
Boswell v. State, 275 Ga. 689 (delusional compulsion must justify the act if true)
Watson v. State, 289 Ga. 39 (preservation rule for appellate review of prosecutorial errors)
Nix v. State, 280 Ga. 141 (prohibition on duplicate life sentences for malice and felony murder)
Malcolm v. State, 263 Ga. 369 (sentencing principles related to murder convictions)