Gibbs v. State, 295 Ga. 92

Gibbs was convicted of malice murder, armed robbery, and two counts of possession of a firearm during the commission of a crime in relation to Judson Boyd’s death.
Evidence showed Boyd was beaten and shot; bloodstains and a 9mm shell casing linked Gibbs to the scene.
DNA matched Boyd’s blood to Gibbs’s jeans and car; Gibbs testified with explanations for blood and money at the scene.
Gibbs was found with cash, Percocet, and bruising; his girlfriend Bailey’s residence contained Gibbs’s bloodstained jeans.
The trial court sentenced Gibbs on both firearm counts, but this Court later vacated one of the firearm-convictions sentences as duplicative in light of a single fatal encounter.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for malice murder and felony murder	Gibbs argues insufficient evidence that he killed Boyd.	Gibbs contends blood patterns and other facts could support another culprit.	Evidence rationally supports guilt beyond reasonable doubt.
Whether sentencing on both firearm counts was proper	Convictions supported, so dual firearm sentences valid.	Same handgun and single fatal encounter justify one firearm count sentence.	Vacate the sentence on the firearm during armed robbery; keep the other firearm conviction.

Browder v. State, 294 Ga. 188 (Ga. 2013) (weighing of evidence not done on appeal; rational verdict viewed in light favorable to the verdicts)
Whitaker v. State, 291 Ga. 139 (Ga. 2012) (jury authorized to weigh expertise and other evidence)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review requires proof beyond reasonable doubt)
Blevins v. State, 291 Ga. 814 (Ga. 2012) (sufficiency of armed-robbery evidence with recovered pills and cash)
State v. Marlowe, 277 Ga. 383 (Ga. 2003) (one handgun used in two offenses; consolidate sentences)
Carero v. State, 277 Ga. 867 (Ga. 2004) (vacaturating duplicative firearm sentence)