Collins v. State
290 Ga. 505
| Ga. | 2012Background
- Appellant Kenyatti Collins appeals his murder conviction; approximately two to three weeks before Aug. 20, 2007, Durden's body was found after termination of a relationship with Calloway, a mutual acquaintance.
- Calloway testified Collins was seen with Durden days before Durden's death; Collins later appeared with torn clothes and scratches, claiming a fight with the victim.
- Durden's body showed blunt force trauma; left-handed Collins had blood evidence on a cigarette butt and a fingerprint on the back door knob; a blood-stained shorts in a bag linked to Collins contained both his and Durden's DNA.
- Medical examiner concluded death caused by blunt force trauma; time of death two to three weeks prior to discovery.
- Evidence, viewed in the light most favorable to the verdict, supported a rational jury finding Collins guilty beyond a reasonable doubt of the charged crimes.
- During trial, there was a challenged chain-of-custody issue for the victim's blood sample; a juror-contact issue arose when a victim’s relative spoke to a juror, later found inconsequential.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the DNA and fingerprint evidence | Collins argues DNA and fingerprint evidence fail to establish custody and identity. | State asserts proper foundation and typical handling establish admissibility. | Evidence sufficient to support conviction. |
| Chain-of-custody foundation for victim's blood | State failed to prove entry of the blood sample's chain of custody through all handlers. | Testimony from medical examiner and forensic biologist created reasonable certainty of identity. | Trial court did not abuse discretion; foundation adequate. |
| Prejudice from juror-contact with victim's family | Improper contact threatened fair trial; prejudice presumed. | Contact was inconsequential and did not prejudice defendant. | No reversible error; contact deemed inconsequential. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. (1979)) (sufficiency review; rational juror verdict standard)
- Vega v. State, 285 Ga. 32 (Ga. 2009) (credibility and conflicts for jury determination)
- Palmer v. State, 250 Ga. 219 (Ga. 1982) (proof of identity of fungible substance need not testifying custodian)
- Schlanger v. State, 290 Ga. App. 407 (Ga. App. 2008) (tampering concerns; no requirement to foreclose all tampering possibilities)
- Herrera v. State, 288 Ga. 231 (Ga. 2010) (proper foundation for DNA evidence)
- Jones v. State, 289 Ga. 111 (Ga. 2011) (improper communication with juror; preservation of impartiality)
- Sims v. State, 266 Ga. 417 (Ga. 1996) (presumption of prejudice when juror contact occurs)
- State v. Clements, 289 Ga. 640 (Ga. 2011) (improper communications with jurors can be inconsequential)