Daniels v. State, 298 Ga. 120

Victim Latrenda Jennings was found April 21, 1991, strangled with a belt; injuries included a bleeding vaginal laceration and abrasions suggesting struggle.
A sexual-assault kit recovered intact spermatozoa; DNA profile later generated and matched Larry Daniels via CODIS in December 2009.
Daniels had a prior violent sexual assault incident nine months before the murder in the same area; he admitted trading crack for sex and gave inconsistent statements about knowing the victim and being in the area.
Daniels was indicted in 2010 on five counts (malice murder; two alternative felony murders; aggravated assault; rape), tried and convicted in 2012; malice murder sentence originally entered as life without parole then amended.
Daniels appealed only the sufficiency of the evidence; the Supreme Court of Georgia affirmed the convictions but found sentencing error as to merger/vacatur and remanded for resentencing on the rape count.

Issue	Plaintiff's Argument (Daniels)	Defendant's Argument (State)	Held
Sufficiency of evidence to convict given DNA alone could reflect consensual sex within 72 hours	DNA evidence could indicate consensual, recent intercourse and thus not prove Daniels was the murderer	DNA matched Daniels, intercourse was temporally close to death, crime scene, injuries, inconsistent statements, and prior violent sexual assault support guilt	Evidence sufficient for a rational juror to find guilt beyond a reasonable doubt
Proper application of merger and sentencing for underlying felonies	(not argued to alter outcome) Daniels challenged sentencing consequences implicitly	Trial court merged aggravated assault and rape into vacated felony-murder counts for sentencing	Trial court erred: alternative felony-murder counts were vacated by operation of law; aggravated assault merged factually into malice murder but rape did not — remand for resentencing on rape count

Jackson v. Virginia, 443 U.S. 307 (establishes standard for reviewing sufficiency of the evidence)
Walker v. State, 282 Ga. 406 (supports inference rejecting consensual-sex hypothesis given totality of evidence)
Hulett v. State, 296 Ga. 49 (explains that alternative felony-murder counts are vacated by operation of law and merger must be analyzed to malice murder)
Malcolm v. State, 263 Ga. 369 (principle that vacated felony-murder counts cannot serve as merger targets)
Merritt v. State, 285 Ga. 778 (circumstantial-evidence rule: must exclude every reasonable hypothesis save guilt)
Roberts v. State, 296 Ga. 719 (same circumstantial-evidence standard discussion)