Davis v. State
294 Ga. 486
| Ga. | 2014Background
- Davis lived with the victims, Chambers and Marsingill, in their home.
- On Feb. 28, 2005, Davis called police reporting an intruder and claimed he was locked in a room with a loaded shotgun.
- Police found Chambers and Marsingill dead, stabbed many times, with bleach odors and signs of attempted cleaning; knives and bleach were found in Davis’s room.
- There was no forced entry or ransacking; a note from Davis suggested fear or departure, and testimony indicated Chambers feared Davis.
- Evidence, including the note and relationship dynamics, sufficed for a reasonable jury to convict beyond a reasonable doubt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence supports conviction beyond a reasonable doubt | Davis argues insufficiency of the evidence | State maintains sufficient evidence proved guilt | Conviction affirmed on sufficiency |
| Whether Chambers’ fear statement was admissible under the necessity exception | Chambers’s fear statement lacked necessity | Statement was trustworthy and highly probative given Chambers’s murder | Admissible under necessity exception |
| Whether trial counsel was ineffective for admitting shotgun/knives evidence | Counsel failed to object to yes | Evidence relevant to crime and consistent with defense strategy | No ineffective assistance; trial strategy supported admissibility |
| Whether trial counsel was ineffective over closing argument | Objection to prosecutor’s comments could have altered outcome | Judge properly instructed burden of proof; statements not reversible error | No ineffective assistance; not outcome determinative |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for criminal conviction)
- Mathis v. State, 291 Ga. 268 (Ga. 2012) (necessity exception to hearsay; trustworthy when related by close associate)
- Wright v. State, 291 Ga. 869 (Ga. 2012) (standard for ineffective assistance review)
- Hayes v. State, 263 Ga. 15 (Ga. 1993) (presumed adherence to trial court instructions on burden of proof)
- Holmes v. State, 273 Ga. 644 (Ga. 2001) (juror compliance with instructions on burden)
- Starks v. State, 283 Ga. 164 (Ga. 2008) (ineffective assistance framework; Strickland standard)
- Fuller v. State, 277 Ga. 505 (Ga. 2004) (ineffective assistance analysis)
- Robinson v. State, 277 Ga. 75 (Ga. 2003) (trial court findings reviewed for error)