Hayes v. State
292 Ga. 506
| Ga. | 2013Background
- Hayes appeals her convictions for malice murder and possession of a firearm during the commission of a felony related to the shooting death of Heather Strube.
- Evidence included eyewitness identification, surveillance observations, and Hayes’ statements to others.
- There were allegations that surveillance footage quality and media coverage affected identifications.
- Hayes provided alibi-like statements and other circumstantial details about her movements and possible alibi logistics.
- The jury ultimately found Hayes guilty and the trial court denied a motion for new trial; this Court affirmed the judgments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the evidence sufficient to convict Hayes of malice murder and related offenses? | Hayes contends the evidence was insufficient. | State argues the evidence, viewed in the light most favorable to the verdict, supported guilt beyond a reasonable doubt. | Yes; the evidence authorized a guilty verdict on all charges. |
| Were eyewitness identifications and related testimony reliable given media coverage and surveillance quality? | Hayes argues identifications were unreliable due to publicity and video quality. | State contends credibility and weight are for the jury to assess. | Issues go to weight; sufficient evidence supported verdict despite identification concerns. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (standard for sufficiency of the evidence; no reweighing by appellate courts)
- Mickens v. State, 277 Ga. 627 (Ga. 2004) (review for weight of the evidence and witness credibility; jury prerogative)
- Robbins v. State, 269 Ga. 500 (Ga. 1998) (circumstantial-evidence standard; exclude reasonable hypotheses beyond guilt)
- Tolbert v. State, 282 Ga. 254 (Ga. 2007) (credibility and conflicts in the evidence entrusted to the jury)
- Malcolm v. State, 263 Ga. 369 (Ga. 1993) (merger of counts and related procedural posture)