Chua v. State
289 Ga. 220
| Ga. | 2011Background
- Carter died December 15, 2005 from self-inflicted drug intoxication (morphine, oxycodone, methadone) prescribed by Chua.
- Chua, a physician, prescribed the drugs and other analgesics; Carter lived in Chua's home and worked in his office.
- State charged Chua with multiple VGCSA violations and felony murder based on prescriptions not for legitimate medical purpose or usual course.
- Jury convicted on several counts; some counts merged with felony murder; Chua received life for felony murder and other terms.
- On appeal, Georgia Supreme Court affirms in part and vacates in part, addressing sufficiency, causation, dwelling-keeping, and evidentiary issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence under OCGA 16-13-41(f) | State | Chua | Evidence sufficient to convict |
| Felony murder proximate cause of death | State | Chua | Proximate causation established |
| Conviction under OCGA 16-13-42(a)(5) maintaining dwelling used for controlled substances | State | Chua | Vacated conviction |
| Admission of independent acts (similar transaction) evidence | State | Chua | Admissible for proper purposes |
| Good faith jury instruction on prescribing | State | Chua | Charge adequate; no error |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1989) (sufficiency standard applies; defer to jury weight)
- Greeson v. State, 287 Ga. 764 (2010) (standard for reviewing sufficiency in Georgia)
- Hulme v. State, 273 Ga. 676 (2001) (felony murder requires inherently dangerous felony)
- Durden v. State, 250 Ga. 325 (1982) (causal link in felony murder proximate cause)
- Barnes v. State, 255 Ga. 396 (1986) (continuing conduct; proper evaluation of evidence)