Chapa v. State, 288 Ga. 505

Chapa was convicted of malice murder of Charlie Hendrix and challenged the denial of his motion for new trial.
Evidence showed Hendrix alive when his brother visited on Nov 23, 2001 and dead next morning from multiple injuries and throat cut.
Blood found inside Hendrix's home on numerous items; appellant claimed he had not been inside the home and had no injuries linking him to blood.
Ledesma testified appellant was driven to Hendrix's home to borrow money and returned with blood on him and his shirt; jailhouse informants reported threats and admissions.
Defense argued blood evidence did not establish appellant as the source and that others could have committed the murder; jury resolved credibility issues in favor of guilt.
Court affirmed rejecting sufficiency and procedural challenges, including absence of preserved objections to closing and voluntary manslaughter instruction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence excludes reasonable hypotheses other than guilt	Chapa argues lack of direct blood link and alternate suspects create reasonable doubt.	State contends circumstantial evidence suffices when reasonable jurors reject alternatives.	Evidence sufficient to support guilt beyond reasonable doubt.
Whether prosecutorial closing argument conduct was improper	Chapa claims closing referenced his failure to testify.	State asserts remark not directed to silence and was non-prejudicial.	No reversible error; not preserved and not reasonably interpreted as comment on silence.
Whether trial court erred by not instructing on voluntary manslaughter	Chapa seeks lesser-included offense instruction.	State notes no written request for such instruction; standard waiver applies.	Waived; charge given did not misstate guidelines for guilt/innocence.

Brooks v. State, 281 Ga. 514 (2007) (jury may resolve credibility; circumstantial evidence can be sufficient)
Treadwell v. State, 285 Ga. 736 (2009) (rejects theoretically possible but unreasonable alternatives)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency review)
Wellons v. State, 266 Ga. 77 (1995) (preservation and interpretation of prosecutorial remarks)
Kennedy v. State, 277 Ga. 588 (2004) (unrequested jury instruction waived unless clearly erroneous)
Smith v. State, 277 Ga. 213 (2003) (unrequested charges and waiver considerations)
Butler v. State, 273 Ga. 380 (2001) (preservation requirements for closing argument objections)