Geiger v. State
295 Ga. 648
Ga.2014Background
- Geiger was convicted after a jury trial of murder, felony murder, armed robbery, kidnapping, and related offenses for the Bacon cousins' deaths.
- The State presented prior offenses as similar transactions to show pattern, motive, and identity.
- Co-defendant Smith testified Geiger forced victims into a grave and shot them; a letter corroborated admission by Geiger.
- A shell casing linked to Geiger’s pistol was found at the crime scene in 2005, later tied to the 2003 arrest gun.
- Geiger sought additional continuances to retest shell casings and obtain another witness; relief was denied.
- Geiger raises ineffective assistance claims for counsel: not calling Latoya Brewton, failing to retest shell casing, and failing to object to character evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Geiger challenges the verdict as unsupported | State had sufficient proof beyond a reasonable doubt | Evidence sufficient to sustain verdict |
| Admission of similar transactions | State’s similar crimes were improperly admitted | Similar transactions properly admitted to show plan/motive | Admissible; proper analysis of similarities and purposes |
| Second continuance for testing and witness | Second continuance necessary for independent testing and new witness | No abuse of discretion; testing and witness not shown to benefit defense | No reversible error; denial affirmed |
| Improper character evidence (shackles and prior incarceration) | Shackling and prior incarceration were improper character evidence | Admission was permissible or non-prejudicial | No reversible error; evidence properly admitted or harmless |
| Ineffective assistance of counsel | Counsel deficient for not locating Latoya Brewton, not testing shell casing, and failing to object to evidence | Strategic decisions and lack of prejudice negate ineffectiveness | No ineffective assistance; decisions were reasonable and not prejudicial |
Key Cases Cited
- Matthews v. State, 294 Ga. 50 (2013) (establishes criteria for admissibility of similar transactions)
- Stephens v. State, 261 Ga. 467 (1991) (general rule against admissibility of other crimes; exceptions for identity/motive/plan)
- Collum v. State, 281 Ga. 719 (2007) (admissibility of similar transactions under exceptions)
- Daniels v. State, 281 Ga. 226 (2006) (focus on similarities rather than differences)
- Gates v. State, 244 Ga. 587 (1979) (shackling in court generally disfavored but not prejudicial by itself)
- Rhodes v. State, 264 Ga. 123 (1994) (curative instructions; voir dire on prejudicial effects)
- Williams v. State, 317 Ga. App. 248 (2012) (prejudice shown through lack of defense impact for continuance denial)
- Hayes v. State, 262 Ga. 881 (1993) (failure to object to admissible evidence not ineffective assistance)
- Kitchens v. State, 289 Ga. 242 (2011) (overwhelming evidence can render some evidentiary errors harmless)
- Ross v. State, 255 Ga. 1 (1985) (relevance of defendant's prior arrest to current charges; admissible)