Dillard v. State, 297 Ga. 756

Victim Sandra Knight was found dead from strangulation April 14, 2007; Dillard was indicted for malice and felony murder and convicted of malice murder after a May 2011 jury trial and sentenced to life.
On the night of the killing, Dillard and the victim left a party, stopped to buy crack, returned to Dillard’s home; Dillard called 911 and claimed the victim collapsed after using drugs and earlier reported being choked by an unknown person.
Investigators observed fresh neck scratches and sexually disarranged clothing inconsistent with emergency care; seven party witnesses said the victim appeared unharmed that night.
Dillard gave multiple voluntary statements to police over several days (at his home, while giving samples, at the station), and only received Miranda warnings during a final GBI interview, which he terminated.
The State introduced evidence of six prior incidents (1991–2005) involving sexual/physical abuse, choking, and rape attempts to show bent of mind, course of conduct, intent, and lustful disposition.
Dillard challenged sufficiency, admission of statements (Miranda/custody), admission of similar transactions, and a four‑year pretrial delay as violating his speedy trial right; the Supreme Court of Georgia affirmed the conviction.

Issue	Plaintiff's Argument (Dillard)	Defendant's Argument (State)	Held
Sufficiency of evidence	Evidence insufficient to prove malice murder beyond reasonable doubt	Evidence (forensic findings, injuries, inconsistent explanations) supports malice murder	Affirmed — evidence sufficient under Jackson v. Virginia
Admissibility of statements / Miranda custody	Statements were products of custodial interrogation and should be suppressed for lack of Miranda warnings	Dillard was not in custody or restrained to arrest degree; statements were voluntary so Miranda not required	Affirmed — no custodial interrogation; warnings not required
Admission of similar transaction evidence	Prior acts were unfairly prejudicial and cumulative; barred as character evidence	Prior acts were similar in victim profile and modus operandi, admissible to show bent of mind, intent, course of conduct	Affirmed — trial court did not abuse discretion admitting six similar transactions after Rule 31.3 hearing
Speedy trial (four‑year delay)	Delay (indictment to trial ~4 years) was presumptively prejudicial and violated speedy trial rights	Much delay due to court resource limitations and a State interlocutory appeal; defendant delayed asserting the right and did not show prejudice	Affirmed — although delay was long and reason for delay should weigh lightly against State, Dillard’s late assertion and lack of demonstrated prejudice foreclose relief

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)
Miranda v. Arizona, 384 U.S. 436 (1966) (requirement of warnings when a suspect is in custody)
Barker v. Wingo, 407 U.S. 514 (1972) (four‑factor speedy trial balancing test)
Doggett v. United States, 505 U.S. 647 (1992) (presumptive prejudice from excessive delay)
Ruffin v. State, 284 Ga. 52 (2008) (Georgia application of Barker factors and analysis of state delay causes)
Williams v. State, 261 Ga. 640 (1991) (requirements for admitting similar transaction evidence under Rule 31.3)
Hardin v. State, 269 Ga. 1 (1998) (officer’s undisclosed suspicions do not make questioning custodial)
Freeman v. State, 295 Ga. 820 (2014) (admission of non‑custodial statements)