Haslam v. the State
341 Ga. App. 330
| Ga. Ct. App. | 2017Background
- Defendant Devon Haslam appealed an out-of-time conviction arising from one of three consolidated indictments; he challenges sufficiency of evidence for rape and two counts of aggravated sodomy in Case No. A17A0227.
- Victim (a woman who had placed an advertisement and was working as a prostitute) arranged to meet Haslam at a hotel; Haslam entered her room and grabbed her by the neck, threatened her, and ordered sexual acts.
- The victim testified Haslam forcibly penetrated her vaginally and anally multiple times, forced oral sex, caused anal bleeding and pain, took her money and phone, severed the hotel phone, and bound and gagged her before leaving.
- A post‑attack medical exam showed possible vaginal and anal injuries consistent with forcible penetration.
- Haslam pointed to inconsistencies among the victim’s statements to her boyfriend, health workers, and law enforcement (e.g., how she met him, whether she was working as a prostitute, details of acts performed) and argued those inconsistencies rendered the evidence insufficient.
- The jury convicted Haslam of rape, aggravated sodomy, false imprisonment, robbery by force, and hindering an emergency call; the Court of Appeals reviewed sufficiency of the evidence under Jackson v. Virginia.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient to support convictions for rape and aggravated sodomy | Haslam: Victim’s inconsistent statements and discrepancies undermine credibility and thus evidence is insufficient | State: Victim’s consistent assertion of sexual assault, testimony of forcible penetration, corroborating medical findings and other facts provide competent evidence of each element | Court affirmed — evidence sufficient to support rape and aggravated sodomy convictions |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)
- Walker v. State, 267 Ga. App. 155 (2004) (jury credibility determinations; appellate standard of review)
- Ruffin v. State, 333 Ga. App. 793 (2015) (victim’s testimony alone can support conviction)
- Bradberry v. State, 297 Ga. App. 679 (2009) (direct and circumstantial evidence of forcible rape where intercourse was painful)
- Vega v. State, 285 Ga. 32 (2009) (conflicts or inconsistencies in evidence are for the jury to resolve)