Haufler v. State, 315 Ga. 712

In August 2018 Marc Dimos was found beaten and shot in the basement of Chad Haufler’s home; Haufler was arrested and indicted for malice murder, felony murder, aggravated assault/battery, and firearm possession.
Officers found no forced entry; forensic evidence showed multiple blunt-force facial injuries, two separate blood pools, and a gunshot to the face from a downward 20-degree angle at least 18 inches away.
Haufler repeatedly told officers (on dash-cam recordings) that after being put in a chokehold he went upstairs, retrieved his Glock .40 and shot the victim; he made similar statements before and after a deputy coroner questioned him in the patrol car.
Defense experts offered (1) a blackout theory from heavy drinking and (2) an alternative struggle/discharge theory; prosecution experts and physical evidence supported that Haufler shot Dimos after gaining the upper hand.
At trial Haufler requested an involuntary manslaughter instruction (misdemeanor and/or felony), which the court denied; he also moved to suppress statements made to the deputy coroner, which the court denied after a Jackson–Denno hearing.
The jury convicted Haufler of malice murder and related counts; the Georgia Supreme Court affirmed, concluding any instructional or evidentiary error was harmless.

Issue	Haufler's Argument	State's Argument	Held
Trial court refused an involuntary manslaughter instruction	Slight evidence supported involuntary manslaughter (intoxication/blackout, accidental discharge, recklessness or criminal negligence)	No affirmative evidence of negligent/reckless handling or accidental discharge; evidence showed intentional shooting and aggravated assault	Even if charge should have been given, any error was harmless given overwhelming evidence of malice murder and the incriminating statements/evidence
Denial of motion to suppress statements to deputy coroner in patrol car (Miranda)	Statements were made while in custody and during interrogation; Miranda warnings required	Haufler was not in custody; deputy coroner lacked police powers so Miranda inapplicable; and, statements were voluntary and/or cumulative of other admissions	Trial court’s factual findings accepted; in any event any error was harmless beyond a reasonable doubt because the same admissions were made before and after the coroner’s questioning

Moon v. State, 311 Ga. 421 (2021) (slight evidence standard for giving involuntary manslaughter charge)
Wade v. State, 304 Ga. 5 (2018) (de novo review whether evidence warranted a requested instruction)
McIver v. State, 314 Ga. 109 (2022) (mens rea for misdemeanor involuntary manslaughter is criminal negligence)
Soto v. State, 303 Ga. 517 (2018) (lesser-offense evidence must at least exist in the record)
Shah v. State, 300 Ga. 14 (2016) (nonconstitutional harmless-error standard: highly probable error did not contribute to verdict)
Howard v. State, 307 Ga. 12 (2019) (erroneous jury charge reversible only if it caused harm)
Rogers v. State, 289 Ga. 675 (2011) (no reversible error in refusing involuntary manslaughter charge where record overwhelmingly supports malice murder)
Daddario v. State, 307 Ga. 179 (2019) (Miranda generally inapplicable to officials without police powers)
Jackson v. Denno, 378 U.S. 368 (1964) (pretrial hearing on voluntariness of statements)
Jones v. State, 314 Ga. 605 (2022) (constitutional error harmless when evidence is cumulative or State’s case is overwhelming)
Overton v. State, 305 Ga. 597 (2019) (pointing a firearm that places victim in reasonable apprehension may constitute aggravated assault rather than a mere misdemeanor)