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