Griffin v. State
292 Ga. 321
| Ga. | 2013Background
- Griffin and Boyd were convicted of felony murder based on aggravated assault of Clark; Griffin also convicted of aggravated assault against Rosson and simple battery of Clark.
- April 11, 2006: Griffin and another man go to Clark’s home to collect a drug debt; Griffin threatens Rosson with a razor.
- Following an unrelated June 2006 encounter, Griffin strikes Clark from behind; Boyd joins and they beat Clark as he lies on the ground.
- Clark dies three weeks later from blunt force head trauma and blows to the torso; victim was left by the road and later found alive.
- Evidence supported a rational verdict on all charges; Griffin’s admission was not the sole basis for felony murder.
- Appellants appealed after the trial court denied new trials; the Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of felony murder based on aggravated assault | Griffin argues admission alone cannot support felony murder | State contends evidence shows Griffin directly/with Rosson participated in aggravated assault causing death | Evidence sufficient to support felony murder verdict |
| Directed verdict on Rosson aggravated assault | Griffin disputes sufficiency of aggravated assault with deadly weapon | State contends sufficient evidence | No error; evidence supported conviction beyond reasonable doubt |
| Severance of Rosson offense from June 2006 offenses | Griffin/ Boyd claim severance required to prevent prejudice | State argues court did not abuse discretion; evidence admissible for motive | No abuse of discretion; severance denied not reversible error |
| Admission of Rosson’s statements and confrontation issue | Griffin challenges confrontation rights; hearsay objection considered | State argues admissible under OCGA § 24-3-2; any error harmless | Harmless beyond reasonable doubt; statements cumulative and not prejudicial |
| Ineffective assistance of counsel claims | Griffin asserts multiple failures (preparation/investigation, objections) | State contends decisions were strategic; no deficient performance | Claims fail under Strickland; no ineffective assistance proven |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review standard for criminal convictions)
- Skaggs v. State, 278 Ga. 19 (Ga. 2004) (evidence of head blows can support felony murder via aggravated assault)
- Smith v. State, 290 Ga. 428 (Ga. 2012) (sufficiency review for directed verdict under OCGA § 16-5-21)
- Jones v. State, 280 Ga. 205 (Ga. 2005) (credibility and evidentiary conflicts resolved by jury)
- Heard v. State, 287 Ga. 554 (Ga. 2010) (admissibility of prior-crime evidence to show motive; proper admonitions to jury)