Goins v. State, 306 Ga. 55

Appellant Charmane Goins was indicted for malice murder, felony murder, and aggravated assault in connection with Lauren Taylor’s October 2014 strangling and subsequent burning; jury convicted him and he received life without parole for malice murder.
Relevant evidence: Appellant’s alleged confession to a former cellmate that he strangled Taylor with a seatbelt; cell‑phone records placing him near Gwinnett County the night of the killing; recanted alibi from friend Karl Wyatt; pawned guitar belonging to a third party; Appellant testified with a different alibi at trial.
Appellant was arrested December 22, 2014; trial began August 28, 2017 (≈32 months later). A pre‑indictment speedy‑trial demand was reportedly filed earlier but not ruled on; counsel requested continuances; first lawyer suffered a stroke in December 2016.
Appellant filed a pretrial motion to dismiss on speedy‑trial grounds (March 2017); trial court orally denied it in May 2017 but made limited findings and entered no written order.
After conviction, Appellant raised a constitutional speedy‑trial claim in a motion for new trial; the trial court denied the motion by summary order without making findings of fact and conclusions of law on the Barker factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support malice murder conviction	Evidence was circumstantial and unpersuasive; thus insufficient under OCGA § 24‑14‑6	Evidence (including a confession to a cellmate, cell‑phone records, pawned property, witness testimony) supports guilt beyond a reasonable doubt	Conviction affirmed; evidence sufficient when viewed in light most favorable to verdict (Jackson standard)
Constitutional speedy‑trial violation	32‑month delay between arrest and trial, alleged delays attributable to prosecution and system; appellant repeatedly demanded trial	State and trial court attributed most delay to defense continuances and counsel’s illness; trial court denied dismissal	Trial court’s denial vacated in part and remanded because it failed to make required factual findings and legal conclusions under Barker; appellate court did not decide merits

Willis v. State, 304 Ga. 781 (discussing standard for circumstantial evidence and reasonable alternative hypotheses)
Jackson v. Virginia, 443 U.S. 307 (constitutional standard for sufficiency of the evidence review)
Vega v. State, 285 Ga. 32 (deference to jury credibility determinations)
Pickett v. State, 288 Ga. 674 (presumptive‑prejudice threshold and speedy‑trial framework)
Johnson v. State, 300 Ga. 252 (Barker factors and requirement for trial‑court findings)
Barker v. Wingo, 407 U.S. 514 (four‑factor speedy‑trial balancing test)
Doggett v. United States, 505 U.S. 647 (speedy‑trial prejudice considerations)
Higgenbottom v. State, 288 Ga. 429 (imperative that trial court enter findings of fact and conclusions of law on speedy‑trial claims)