DAVIS v. THE STATE (Two Cases)
306 Ga. 140
| Ga. | 2019Background
- On Nov. 15, 2014, T’arsha Williams was killed and Julius Larry wounded after meeting with William Davis, Trinika Beamon, and Taylor LaCount following contact at a nightclub; LaCount pleaded guilty and testified for the State.
- Davis, Beamon, and LaCount arranged a meeting that led to an attempted robbery; an unidentified armed man approached the victims’ car, shots were exchanged, and Williams was killed.
- A Chatham County grand jury indicted Davis and Beamon for felony murder (predicated on attempted armed robbery and aggravated assault), attempted armed robbery, aggravated assault, attempted armed robbery of Larry, and conspiracy. LaCount is not on appeal.
- After a June 2017 jury trial both Davis and Beamon were convicted on all counts; Davis received life plus a consecutive 20 years, Beamon life with a concurrent 15-year count; several counts were merged or vacated.
- Both defendants filed motions for new trial raising multiple claims: Davis challenged sentencing (rule of lenity) and asserted numerous ineffective-assistance claims; Beamon challenged the constitutionality (facial and as-applied) of Georgia’s felony-murder statute and sufficiency of the evidence. The trial court denied their motions and the Supreme Court of Georgia affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to convict (both) | Beamon (and Davis in part) argued evidence was insufficient to support convictions | State: testimony, surveillance, and LaCount’s cooperation corroborated guilt | Affirmed — evidence sufficient for convictions under Jackson v. Virginia standard |
| Rule of lenity / sentencing (Davis) | Davis argued court should have applied lenity to impose aggravated-assault-with-intent-to-rob sentence instead of attempted armed-robbery | State: Davis was convicted of attempt to commit armed robbery and sentenced accordingly; lenity does not permit imposing a different offense than the one of conviction | Denied — lenity inapplicable; convictions and sentence for attempted armed robbery stand |
| Ineffective assistance of counsel (Davis; multiple subclaims) | Davis contended trial counsel made numerous errors (failed objections to opening, exhibits/photos, expert hypotheticals, cross of LaCount, detective testimony, and closing) causing prejudice | State: most challenged omissions were tactical, objections would likely have failed, or no prejudice shown under Strickland test | Denied — Davis failed to show deficient performance and resulting prejudice; cumulative-error claim also fails |
| Constitutionality of felony-murder statute (Beamon) — facial challenge | Beamon argued OCGA § 16-5-1(c) is vague (Ford decision creates unpredictability) and thus unconstitutional on its face | State: statute gives fair notice; Ford narrows possible predicates but does not render statute void for vagueness | Denied — statute not facially invalid; Ford provides limiting principle but does not make statute vague |
| Constitutionality of felony-murder statute (Beamon) — as-applied challenge | Beamon argued application here (her greater sentence vs LaCount) is unfair and thus statute unconstitutional as applied | State: sentencing disparities and prosecutorial charging/plea decisions do not render statute unconstitutional as applied | Denied — no cognizable as-applied constitutional defect shown |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (established standard for sufficiency review)
- Strickland v. Washington, 466 U.S. 668 (two-prong ineffective-assistance test)
- State v. Hanna, 305 Ga. 100 (2019) (limitation on rule of lenity application)
- Ford v. State, 262 Ga. 602 (1992) (felony-murder predicate limited to felonies dangerous per se or creating foreseeable risk of death)
- Jones v. State, 299 Ga. 40 (2016) (permissible scope when a witness’s testimony aligns with investigative evidence without directly attesting to another witness’s veracity)
- Plez v. State, 300 Ga. 505 (2017) (photographs depicting a body or crime scene are not automatically inadmissible as gruesome under Rule 403)
- Moss v. State, 298 Ga. 613 (2016) (counsel not required to make objections reasonably believed to fail)