Goss v. State
312 Ga. App. 676
Ga. Ct. App.2011Background
- Goss challenges conviction for trafficking in cocaine and selling cocaine.
- State admitted evidence of two similar transactions (2006 and 2007) to prove knowledge, intent, and bent of mind.
- 2006 incident: Goss in car stopped on GA 400; cash, firearm, and five bags of cocaine found; officer testified to sale implication.
- 2007 incident: Goss arrested on warrant; bags of cocaine and opium found; cash indicates distribution.
- Goss testified coerced into selling by co-defendant Wright who allegedly threatened him with a weapon.
- Trial court allowed the similar-transaction evidence and gave a limited purpose jury instruction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of similar transactions | Goss contends evidence is insufficiently similar. | Goss argues admissibility violates probative-similarity rule. | Court affirmed, no abuse of discretion. |
Key Cases Cited
- Williamson v. State, 300 Ga. App. 538 (2009) (abuse-of-discretion standard for similar-transaction evidence)
- Gaudlock v. State, 310 Ga. App. 149 (2011) (focus on similarities, not differences)
- Vaughan v. State, 251 Ga. App. 221 (2001) (distinguishes improper similarity in other contexts)
- King v. State, 230 Ga. App. 301 (1998) (distinguishes earlier similar-transaction limits)
- King v. State, 242 Ga. App. 642 (2000) (distinguishing related‑fact similarities)