Bunnell v. State, 292 Ga. 253

Bunnell, age 46, lived with Margie Eason for about seven years and cared for her in exchange for room and board.
Each owned a life insurance policy listing the other as beneficiary.
On the day of Eason's death, Bunnell sought money to buy cigarettes; surveillance shows him in a store later that afternoon.
Eason was found dead with blunt head trauma, no forced entry, and signs suggesting a violent struggle; an ax handle with blood and hairs was present.
Bunnell gave police a videotaped account admitting he struck Eason with the ax handle and later cleaned up the scene.
Trial court admitted the challenged evidentiary items; the verdict and sentences followed, and the court affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of Bunnell's statement	Bunnell argues the statement was involuntary due to misstatements of law.	State contends the waiver was knowing and voluntary under totality of circumstances.	Statement admissible; voluntary and properly admitted.
Hearsay testimony under the necessity exception	Hearsay statements show relationship dynamics relevant to the case.	Necessity exception applies given unavailability and trustworthiness.	Trial court did not abuse discretion; necessity exception upheld.
Mistrial due to character evidence	Evidence of a DUI suspension should have triggered mistrial.	Any prejudice remedied by curative instruction; evidence was inadvertent and outweighed by guilt.	No mistrial; curative instruction adequate.
Post-autopsy photographs	Photos were cumulative and inflammatory.	Autopsy photos shown material facts about head injuries.	Photographs admissible; material facts supported by autopsy.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard; rational trier of fact)
Vergara v. State, 283 Ga. 175 (Ga. 2008) (totality-of-the-circumstances test for voluntariness)
Humphreys v. State, 287 Ga. 63 (Ga. 2010) (admissibility based on voluntariness standard)
McNaughton v. State, 290 Ga. 894 (Ga. 2012) (necessity and trustworthiness in hearsay rulings)
Wallace v. State, 279 Ga. 26 (Ga. 2005) (direct evidence can exist alongside circumstantial evidence)