Crawford v. State
297 Ga. 680
| Ga. | 2015Background
- Appellant Jeremy Crawford and co-defendant William Shelton were found guilty of malice murder and robbery by force in the death of Matthew Proctor; Crawford was sentenced to life.
- Evidence showed they rode with the victim, restrained him at a bridge, beat and strangled him, placed the body in the trunk, and later disposed of it in Pike County.
- Crawford told Giles that they killed the victim and stole his car and money; Giles testified about Crawford's statements and showing the body.
- The body was hidden for days, then buried; the car was later involved in a crash leading to discovery of blood and the body.
- Crawford challenged closing arguments and venue; the court affirmed the verdict, holding sufficiency of evidence and venue proper.
- The procedures and standards applied include Jackson v. Virginia for sufficiency and relevant Georgia venue and evidentiary standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there sufficient evidence for guilt beyond a reasonable doubt? | Crawford argues insufficient evidence. | State contends the record supports guilt beyond reasonable doubt. | Yes; evidence sufficient to support conviction. |
| Was the rope demonstration and four-minute silence in closing argument permissible? | Demonstration was irrelevant and inflammatory. | Demonstration was rooted in evidence and not beyond permissible argument. | No reversible error; demonstration allowed. |
| Was venue properly established in Pike County? | Venue not properly proven beyond reasonable doubt. | Venue established by evidence; jury could determine proper venue. | Yes; venue proper in Pike County. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 ((1979)) (proof beyond a reasonable doubt standard for sufficiency)
- Perry v. State, 274 Ga. 236 ((2001)) (closing argument allowances reflect evidence-based demonstration)
- Norton v. State, 293 Ga. 332 ((2013)) (bounds of permissible argument in closing)
- Braley v. State, 276 Ga. 47 ((2002)) (scope of permissible closing argument)
- Rouse v. State, 296 Ga. 213 ((2014)) (venue determination is juror-determined with statutory standards)
- Jones v. State, 272 Ga. 900 ((2000)) (venue may be established by available proof)