Edenfield v. State, 293 Ga. 370

Edenfield was convicted by jury of murder and related offenses in connection with the sexual assault and death of 6-year-old Christopher Barrios and was sentenced to death for the murder.
Christopher was found in plastic bags; medical examiner testimony showed anal rape, strangulation, bite marks, saliva, and seminal fluid linking Edenfield to the crime.
Edenfield provided inculpatory statements—including participation in sexual assaults and the killing—while Peggy (his wife) testified to Edenfield's involvement.
The State primarily relied on Edenfield's March 16, 2007 statement, with prior interviews contributing to the case; a pretrial suppression motion challenged voluntariness under former OCGA § 24-3-50.
The trial occurred in Glynn County with venue considerations and voir dire conducted in Jeff Davis County due to publicity, with the court later denying change of venue; 156 jurors were examined with limited pretrial publicity affecting only some.
The State used peremptory strikes affecting several jurors; Edenfield challenged Batson procedures; the court upheld the strikes as race-neutral and lacked discriminatory intent; the court also addressed juror qualifications related to sentencing options.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to convict	Edenfield challenges whether the evidence supports the guilty verdicts.	N/A	Evidence supports guilt beyond a reasonable doubt.
Voluntariness of custodial statements	Statements were induced by hope of benefit and thus involuntary under former OCGA § 24-3-50.	Statements were involuntary due to assurances of release or aid.	Trial court did not err; statements were voluntary under totality of circumstances.
Change of venue and pretrial publicity	Venue in Glynn County biased by local publicity; pretrial exposure affected voir dire.	Venue was properly deferred and voir dire in Jeff Davis County ensured impartial jurors.	Court did not abuse discretion; voir dire led to an impartial jury from Jeff Davis County.
Batson racial-discrimination claim	Five of eight strikes were racially motivated to exclude Black jurors.	Strikes based on race-neutral factors; no discriminatory intent shown.	No reversible error; no discriminatory intent established.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (clear standard for sufficiency review: reasonable doubt standard)
Brown v. State, 290 Ga. 865 (Ga. 2012) (hope of benefit and voluntariness under former OCGA § 24-3-50; context matters)
Gissendaner v. State, 272 Ga. 704 (Ga. 2000) (pretrial publicity and venue considerations; evidentiary balancing)
Ledford v. State, 289 Ga. 70 (Ga. 2011) (voir dire discretion and rehabilitation of jurors)
Raheem v. State, 275 Ga. 87 (Ga. 2002) (appellate deference to trial court on juror qualification)
Ellington v. State, 292 Ga. 109 (Ga. 2012) (requirement to consider all three sentencing options; critical facts)