Crowder v. State
294 Ga. 167
| Ga. | 2013Background
- Appellant Darrell Crowder was convicted of malice murder, two counts of felony murder, and related offenses for the 2008 shooting death of his estranged wife, Catcilia Crowder.
- The pre-dawn murder occurred after a break-in at the couple’s home; the victim was found shot multiple times in a bathtub with entry damage visible.
- A 16-year-old daughter witnessed the aftermath and heard gunshots and footsteps; she did not see the shooter.
- Police recovered .45 caliber shell casings at the scene and at Crowder’s mother’s residence; all shell casings and bullets matched a single .45 caliber gun.
- Evidence showed Crowder was at home away from his overnight job in Atlanta around the time of the shooting, with cell data and text exchanges placing him in Newton County.
- Days before the murder, the victim confronted Crowder about an alleged molestation; prior incidents included threats and a crash involving Crowder and the victim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Crowder argues insufficient evidence supports guilt beyond a reasonable doubt. | State asserts overwhelming evidence including motive, opportunity, and DNA links. | Evidence sufficient to sustain conviction. |
| Admissibility of molestation allegation | Molestation evidence should have been excluded as improper character evidence. | Evidence is admissible to show motive, res gestae, and course of conduct. | Admissible; evidence relevant to motive and context. |
| Ineffective assistance for not calling DNA witness | Trial counsel deficient for not calling a DNA witness; prejudice shown. | Uncalled witness testimony would not change outcome; no prejudice shown. | No ineffective assistance; failure to call witness did not prejudice outcome. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (sufficiency review standard for due process)
- Burgess v. State, 292 Ga. 821 (Ga. 2013) (motive evidence admissible in murder cases)
- Merritt v. State, 285 Ga. 778 (Ga. 2009) (motive and contextual evidence relevance)
- Pruitt v. State, 282 Ga. 30 (Ga. 2007) (two-prong test for ineffective assistance of counsel)
- Dickens v. State, 280 Ga. 320 (Ga. 2006) (uncalled witness rule at motion for new trial)
- Reaves v. State, 292 Ga. 545 (Ga. 2013) (unpreserved issues and substitutes for testimony)
- Wright v. State, 291 Ga. 869 (Ga. 2012) (briefs on ineffective assistance standards)