CULAJAY v. State
309 Ga. App. 631
Ga. Ct. App.2011Background
- In May 2006, an undercover officer assisted by a confidential informant investigated Culajay for meth trafficking.
- May 19, 2006: Culajay sold over 50 grams of methamphetamine to the undercover officer.
- May 31, 2006: Culajay sold about 12 grams to the undercover officer and discussed further deals.
- August 2, 2006: undercover operation culminated in a deal for two pounds of methamphetamine; Culajay was arrested at the scene.
- Search warrant following the arrest recovered over 244 grams of methamphetamine at Culajay's residence.
- Culajay was indicted on trafficking and sale counts tied to these dates; a co-defendant was charged on related counts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for trafficking and sale | Culajay argues evidence insufficient to prove trafficking and sale. | Culajay contends no rational juror could find guilt beyond a reasonable doubt. | Evidence supported trafficking and sale convictions beyond reasonable doubt. |
| For-cause juror challenge | Culajay asserts trial court erred in not striking juror for cause. | Culajay contends juror was biased and should have been excused. | Trial court did not abuse its discretion; juror not fixedly opinionated. |
| Admission of jail-related testimony as character evidence | Culajay claims officer's comment about jail was improper character evidence. | Culajay argues the remark prejudicially placed his character before the jury. | Court properly admitted the testimony; it did not place character into evidence. |
Key Cases Cited
- Goolsby v. State, 299 Ga.App. 330 (2009) (standard for sufficiency and jury instructions)
- Jackson v. Virginia, 443 U.S. 307 (1981) (sufficiency review for criminal convictions)
- Chatman v. State, 283 Ga.App. 673 (2007) (for-cause juror challenges and biases)
- Blankenship v. State, 301 Ga.App. 602 (2009) (discretion in denying for-cause challenges)
- Daniel v. State, 296 Ga.App. 513 (2009) (juror bias considerations and ability to follow law)
- Casanova v. State, 285 Ga.App. 554 (2007) (evidence of drug-deal discussions supporting trafficking)