Caldwell v. State
304 Ga. 51
Ga.2018Background
- On March 2, 2009, Walter Caldwell was alone with his girlfriend’s 15‑month‑old daughter, Tynisha; the child was later found dead with extensive blunt‑force and asphyxial injuries.
- Caldwell made multiple statements: initially blaming a fallen television; later admitting he choked the child and apologizing; and ultimately telling police, "I killed her child last night." He waived Miranda rights and gave a statement at the station.
- Medical evidence showed multiple, severe injuries inconsistent with a television accident; cause of death was blunt force trauma to the torso (heart and liver), with hemorrhages and other injuries consistent with choking and blows.
- Caldwell was indicted on five counts (including malice murder, felony murder, aggravated assault, and cruelty to children), convicted on felony murder (while committing aggravated assault) and related counts, and sentenced to life on Count 2; other convictions merged for sentencing.
- On appeal Caldwell challenged the trial court’s refusal to strike prospective Jurors 12, 31, and 35 for cause based on alleged inability to be impartial and improper rehabilitation by the State during voir dire.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court erred in refusing to strike Jurors 12 and 35 for cause | Caldwell: jurors indicated they could not be fair; not rehabilitated; court should have struck them | Trial court: jurors expressed willingness to be fair when examined; any equivocation resolved against challenge | No error shown; even if struck for cause refusal was error, Caldwell failed to show harm because record does not establish those jurors were removed by defense peremptory strikes |
| Whether refusal to strike Juror 31 for cause prejudiced Caldwell | Caldwell: Juror 31 indicated bias and was not rehabilitated by State's questioning | State/trial court: Juror expressed willingness to be fair on individual voir dire; alternate juror ultimately did not serve | Harmless: Juror 31 served only as an alternate and did not sit; no harm shown |
| Whether the State’s leading questions improperly rehabilitated jurors | Caldwell: rehabilitation occurred via improper leading questions by the State during voir dire | State: no contemporaneous objection was made; trial court entitled to resolve equivocations | No reversible error; Caldwell failed to object at trial and accepted selection process at court inquiry |
| Standard of review: whether trial court manifestly abused discretion in juror qualification rulings | Caldwell: trial court abused discretion in refusing cause strikes | State: trial court’s discretion to resolve equivocations; appellate court must defer absent manifest abuse | Court affirms: no manifest abuse; deference to trial court’s resolution of equivocal responses |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of evidence review)
- Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda waiver and warnings principle)
- Nwakanma v. State, 296 Ga. 493 (2015) (no harm where prospective juror removal by State peremptory means defendant lost no strike)
- Heidler v. State, 273 Ga. 54 (2001) (no harmful error where alternate juror not used)
- Thorpe v. State, 285 Ga. 604 (2009) (voir dire must be considered as a whole; trial court resolves equivocations)
- Kass v. State, 297 Ga. 153 (2014) (no requirement to strike juror for expressing doubt; contemporaneous objection to voir dire method required)
- Carter v. State, 302 Ga. 685 (2017) (review for manifest abuse of discretion in juror qualification determinations)
- Dixon v. State, 302 Ga. 691 (2017) (merger of convictions for sentencing discussed)