Currier v. State
294 Ga. 392
| Ga. | 2014Background
- Currier was convicted of felony murder, aggravated assault, concealing the death, and theft of a motor vehicle; sentences include life imprisonment.
- Evidence showed a prior threat about victim speaking, a December 21, 2006 agreed fight, and the victim was rendered unconscious during an assault.
- Co-defendant Hillsman and others were present; victim died soon after the assault, though the medical examiner could not determine exact cause of death.
- Appellant admitted disposing of the body and later told a neighbor; blood found in trailer supported connection to the scene.
- Appellant argued the medical examiner’s inconclusive cause of death invalidated the felony murder conviction; trial included jury charges on involuntary manslaughter.
- Court evaluated whether trial error or ineffective assistance affected verdict; ultimately affirmed the convictions and denied new-trial relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of felony murder evidence | Currier asserts insufficient causation for murder. | State argues totality supports proximate causation. | Sufficient; proximate causation shown |
| Ineffective assistance re involuntary manslaughter instruction | Currier claims trial counsel erred failing to object. | State contends instructions were correct and objections would lack merit. | No deficient performance; no merit in objection |
| Voluntariness of in-custody confession | Currier contends hope of benefit induced confession. | State contends confession voluntary under OCGA 24-3-50. | Voluntary; exhortations to tell truth not a hope of benefit |
| Unanimity instruction impact on deliberations | Currier alleges improper unanimity instruction affected deliberations. | State argues instruction addressed final verdict only, not deliberations. | No reversible error; instructions proper |
Key Cases Cited
- State v. Jackson, 287 Ga. 646 (Ga. 2010) (proximate causation in felony murder context)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard)
- Davis v. State, 290 Ga. 757 (Ga. 2012) (evaluate elements in real circumstances; totality of evidence)
- Irby v. State, 260 Ga. 401 (Ga. 1990) (totality-of-evidence standard for beyond reasonable doubt)
- Richardson v. State, 276 Ga. 548 (Ga. 2003) (murder evidence sufficient without body in some cases)
- Wilson v. State, 285 Ga. 224 (Ga. 2009) (exhortations to tell truth not a 'hope of benefit')
- DeLeon v. State, 289 Ga. 782 (Ga. 2011) (jury charge review for error; holistic approach)
- Duvall v. State, 290 Ga. 475 (Ga. 2012) (counsel not deficient for meritless objections)
- Lowe v. State, 288 Ga. 662 (Ga. 2011) (interpretation of “hope of benefit” for voluntariness)
- Cutrer v. State, 287 Ga. 272 (Ga. 2010) (evidence sufficiency and federal standards applied)