Daughtie v. State
297 Ga. 261
| Ga. | 2015Background
- On Aug. 19, 2010 two victims (Jones and Kyler) were shot after a dark green Chevy TrailBlazer pulled in front of them; Kyler died and Jones survived. Appellant James Daughtie was tried and convicted on eight counts, including malice murder and theft by receiving a stolen handgun.
- Jones identified conduct consistent with an armed ambush; appellant phoned police later that morning reporting a robbery and had a gunshot wound to his leg.
- Police searched appellant’s mother’s house (with her permission) and found blood-stained clothing, Timberland boots, and a 9mm handgun; ballistics linked the handgun to the bullet that killed Kyler, and boot tread could have made a print at the scene.
- At trial the State relied on circumstantial evidence and a recorded statement in which appellant said he found the gun behind a club in North Carolina. The gun’s owner testified it had been stolen in North Carolina.
- Appellant was convicted on all counts and sentenced to life for malice murder plus consecutive terms for other offenses. He appealed, challenging sufficiency of evidence for some convictions, a motion for new trial claim about ballistics testimony, ineffective assistance, and a claim he was absent during a bench conference.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Daughtie) | Held |
|---|---|---|---|
| Sufficiency of evidence for convictions (except theft-by-receiving) | Evidence (ballistics, boots, blood, sequence of events, circumstantial proof) supports convictions beyond a reasonable doubt | Evidence was insufficient to prove guilt beyond a reasonable doubt | Affirmed: evidence sufficient for all convictions except theft-by-receiving under Jackson v. Virginia standard |
| Sufficiency for theft by receiving (knowing receipt of stolen gun) | Appellant’s statement that he found the gun could be disbelieved and treated as substantive evidence of guilt | State failed to prove appellant knew or should have known the gun was stolen; statement that he found it does not show guilty knowledge | Reversed: evidence insufficient to prove knowledge that gun was stolen; jury disbelief of a non-testifying defendant’s statement cannot alone sustain conviction |
| New trial based on alleged misleading ballistics testimony (GBI examiner Felix) | Examiner’s testimony matched bullet to gun; even if issues existed, trial outcome stands | New evidence at motion hearing showed Felix relied on another examiner’s test-fires, undermining credibility and requiring new trial | Denied: trial court properly acted as thirteenth juror; Felix conducted his own test-fire and analysis, so testimony was admissible and no new-trial relief warranted |
| Ineffective assistance re: boot expert and ballistics prep/cross | Trial counsel’s choices deprived Daughtie of effective representation | Counsel failed to object to boot-opinion and failed to investigate Felix’s reliance on another examiner | Denied: counsel made reasonable strategic choices about boot testimony; Felix did his own analysis so additional investigation would not have changed outcome; Strickland standard not met |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence)
- Stacey v. State, 292 Ga. 838 (knowledge a gun is stolen cannot be inferred from mere finding/possession in some contexts)
- Ferguson v. State, 307 Ga. App. 232 (jury disbelief of a testifying defendant may be considered where other corroborative evidence exists)
- United States v. McCarrick, 294 F.3d 1286 (jury disbelief alone cannot sustain conviction absent other probative evidence)
- United States v. Zeigler, 994 F.2d 845 (discussed limits on inferring guilt from demeanor/testimony)
- White v. State, 293 Ga. 523 (trial court’s role as thirteenth juror on motions for new trial)
- Hanson v. State, 263 Ga. App. 45 (admissibility/weight of expert footwear opinion)
- Brown v. United States, 53 F.3d 312 (corroboration required to rely on jury disbelief of defendant’s testimony)