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Hamilton v. State
295 Ga. 295
Ga.
2014
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Background

  • Hamilton was convicted of malice murder and possession of a firearm during a felony in connection with Parrish’s death; the shooting occurred June 21, 2008.
  • Stock s testimony conflicted, but jury could credit him as shooter against prior inconsistent statements.
  • A letter to Parrish’s family allegedly by
  • Handwriting analysis linked a letter to Stocks and Hamilton handwriting samples; Stocks’s sample did not match the Parrish letter.
  • After trial, handwriting and ballistic evidence existed but did not definitively tie Hamilton to the gun or letter; jury weighed circumstantial and direct evidence.
  • Appellate review affirmed the verdicts, denying sufficiency and evidentiary challenges.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of the evidence Hamilton contends evidence fails to show guilt beyond reasonable doubt State argues jury could credit Stocks’s testimony and circumstantial evidence Evidence sufficient to support convictions beyond reasonable doubt
Admission of intoxication testimony Evidence of alcohol/drug use before the shooting is improper character evidence Testimony is res gestae and admissible as part of the events surrounding the crime Testimony properly admitted as res gestae

Key Cases Cited

  • Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for review of sufficiency of evidence)
  • Greeson v. State, 287 Ga. 764 (2010) (defers to jury on weight and credibility of testimony)
  • Vega v. State, 285 Ga. 32 (2009) (jury may credit eyewitness testimony over inconsistencies)
  • Evans v. State, 275 Ga. 672 (2002) (circumstantial evidence and reasonable hypotheses rule)
  • Rogers v. State, 290 Ga. 18 (2011) (reasonableness of hypotheses jury determination)
  • Cunningham v. State, 279 Ga. 694 (2005) (res gestae admissibility of intoxication evidence)
Read the full case

Case Details

Case Name: Hamilton v. State
Court Name: Supreme Court of Georgia
Date Published: Jun 2, 2014
Citation: 295 Ga. 295
Docket Number: S14A0530
Court Abbreviation: Ga.