Clarke v. State, 292 Ga. 305

Clarke was convicted of malice murder and simple assault for the December 10, 2004 attack on Toles in downtown Atlanta.
Albritton and Bock witnessed Clarke strike Toles with a board; Clarke fled, retrieved his candy boxes, and headed toward MARTA after removing Santa attire.
Police detained Clarke near the scene; witnesses identified him as the assailant; Toles died January 21, 2005 from head injuries and related complications.
Clarke challenged whether the evidence proved proximate cause linking his blows to Toles’s death and whether the medical examiner’s conclusions were proper.
Clarke also challenged the trial court’s refusal to strike juror #21 for cause based on impartiality concerns.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of proximate cause for death	Clarke argues the death was due to pre-existing conditions, not his blows.	State contends the head trauma caused the fatal deterioration and the medical examiner linked cause of death to the trauma.	Evidence sufficient to prove proximate causation; conviction affirmed.
Juror #21 for-cause strike	Juror #21's impartiality could be impaired by emotions affecting judgment.	Juror #21 ultimately stated she could be fair and impartial.	No manifest abuse; trial court did not err in not striking Juror #21.

Ward v. State, 238 Ga. 367 (Ga. 1977) (proximate cause guidance for death from injury)
Bishop v. State, 257 Ga. 136 (Ga. 1987) (direct causal connection between injury and death)
Sharpe v. State, 291 Ga. 148 (Ga. 2012) (medical examiner's testimony on manner of death proper)
Raulerson v. State, 268 Ga. 623 (Ga. 1997) (final voir dire distills impartiality)
Poole v. State, 291 Ga. 848 (Ga. 2012) (burden to show partiality rests on the party seeking disqualification)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard for criminal conviction)