Gibson v. State, 300 Ga. 494

Background

Gibson and his father shared a home; Shannon Stanley was a temporary houseguest. Gibson and Stanley had an altercation the morning after Gibson had been out, and Stanley later died of blunt‑force head trauma. Gibson admitted punching Stanley and described other blows; he offered an alternative theory that Stanley fell and struck a van bumper while intoxicated.
A friend Gibson summoned found Stanley injured, blood in the house, and Gibson later called his father, who took Stanley to the hospital; Stanley died January 30, 2011.
Medical testimony: defensive injuries on Stanley’s forearm, no marks on Stanley’s hands consistent with striking someone, swollen hands on Gibson, and the examiner could not identify which blow was fatal but said intoxication was a contributing factor and a fall was unlikely to account for the head‑injuries observed.
Gibson was indicted for malice murder, felony murder, and aggravated assault; convicted by jury (malice murder verdict affirmed; other counts vacated/merged); sentenced to life. He appealed claiming insufficiency of the evidence, erroneous admission of a similar‑transaction, and erroneous exclusion of evidence about Stanley’s reputation for violence.
Trial occurred under Georgia’s pre‑2013 ("old") Evidence Code; the court applied the circumstantial‑evidence rule requiring exclusion of every other reasonable hypothesis, and then‑governing rules on similar transactions and victim‑character evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to support murder conviction	State: circumstantial evidence (injuries, Gibson admissions, medical testimony) excludes reasonable innocent hypotheses	Gibson: forensic evidence and alleged fall are consistent with accidental death; no independent witness to the beating	Evidence sufficient; jury could reject fall theory and find Gibson caused fatal injuries; conviction affirmed
Admissibility of similar‑transaction (2009 assault on father)	State: admitted to show course of conduct, motive, intent; proper exception under old Evidence Code	Gibson: prior act was prejudicial, dissimilar, and remote in time	Admission proper: sufficient similarity (older victim, involvement of girlfriend, blunt‑instrument head blows); probative value outweighed prejudice; no abuse of discretion
Exclusion of evidence of victim’s reputation for violence	Gibson: sought to show Stanley had violent reputation when intoxicated to support justification/self‑defense	State: proffered testimony showed verbal obnoxiousness, not specific violent acts or reputation for violence; defendant failed to make prima facie showing of justification	Exclusion proper: proffer did not show reputation for violence or specific violent acts; defendant failed to establish prima facie case of justification
Prima facie showing required for justification evidence	Gibson: argued past victim behavior while intoxicated should support prima facie justification	State: prima facie must be based on res gestae, not prior incidents or the same evidence offered to establish justification	Court: defendant cannot use the same prior‑act evidence to create the prima facie case; res gestae requirement not met; exclusion upheld

Key Cases Cited

Merritt v. State, 285 Ga. 778 (circumstantial evidence need exclude only reasonable hypotheses)
Black v. State, 296 Ga. 658 (jury role in assessing reasonableness of alternative hypotheses)
Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence)
Lamar v. State, 297 Ga. 89 (standards for admitting similar transactions)
Chua v. State, 289 Ga. 220 (purposes for admitting prior bad acts under old Evidence Code)
Rivers v. State, 296 Ga. 396 (trial court discretion on similarity and probative vs. prejudicial balance)
Quillian v. State, 279 Ga. 698 (limits on victim‑character evidence; reputation vs. verbal misconduct)
Collier v. State, 288 Ga. 756 (prima facie showing required to admit justification evidence)