Flowers v. State, 307 Ga. 618

On Feb. 22, 2014, Jasento Flowers shot and killed his ex‑wife, Bridgette Flowers, at close range and fired at other occupants of her van, injuring several persons. He allegedly later told a family member, “I killed her.”
Appellant was indicted for malice murder, felony murder (merged/vacated), and four counts of aggravated assault; convicted by a jury and sentenced to life without parole plus concurrent 20‑year terms on assault counts.
Prosecution introduced eyewitness testimony and surveillance video of an earlier incident on Feb. 14, 2014, in which the appellant struck Flowers at a Walmart, rendering her unconscious.
The trial court admitted the prior‑acts evidence under OCGA § 24‑4‑404(b) (for motive, preparation, plan) and limited the jury’s consideration to those purposes; appellant objected.
The trial court also admitted an autopsy photograph showing the underside of the victim’s brain; appellant objected as unduly prejudicial, relying on Brown v. State.
On appeal the Georgia Supreme Court affirmed, addressing admissibility of the Feb. 14 beating as other‑acts evidence and admissibility of the autopsy photograph under the current Evidence Code.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Feb. 14 Walmart beating under OCGA § 24‑4‑404(b)	Evidence shows appellant’s motive for killing Flowers; relevant to intent/plan	Beating irrelevant to motive to shoot her later; might show victim would attack appellant, not vice versa	Admitted: prior beating was relevant to relationship and motive; trial court did not abuse discretion
Rule 403 balancing of prejudice vs. probative value for the Feb. 14 beating	Probative value substantial for motive, plan; not overly prejudicial	Prior act would unfairly inflame jury and suggest propensity	Admitted: probative value not substantially outweighed by unfair prejudice
Admissibility of autopsy photograph of exposed brain under Rules 401–403	Photo is probative to show severity and immediate lethality of wound	Photo is unduly prejudicial/gruesome; Brown rule argued to bar autopsy photos unless necessary	Admitted: Brown abrogated; single photo relevant and not overly gruesome; trial court did not abuse discretion

Jackson v. Virginia, 443 U.S. 307 (legal sufficiency standard)
State v. Jones, 297 Ga. 156 (Rule 404(b) framework and abuse‑of‑discretion review)
State v. Atkins, 304 Ga. 413 (three‑part 404(b) test)
Smart v. State, 299 Ga. 414 (prior domestic violence relevant to motive and Rule 403 analysis)
Venturino v. State, 306 Ga. 391 (current Evidence Code governs autopsy photo admissibility)
Plez v. State, 300 Ga. 505 (photographs that fairly depict injuries are not per se inadmissible under Rule 403)
Brown v. State, 250 Ga. 862 (old rule barring autopsy photos after incisions — cited and held abrogated)
United States v. Farish, 535 F.3d 815 (federal precedent recognizing prior domestic abuse evidence probative of motive)