Haynes v. State
317 Ga. App. 400
Ga. Ct. App.2012Background
- Haynes was convicted by a jury on eight counts of sexual exploitation of children.
- The trial court denied his motion for a new trial, and he appeals.
- Haynes challenges sufficiency of evidence, arguing lack of knowledge about child-pornography on his computer.
- The State charged him under OCGA § 16-12-100(b)(8).
- The court applies Jackson v. Virginia and addresses suppression and sentencing issues.
- The court remands for resentencing after applying Hedden v. State.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of knowledge | Haynes lacked knowledge of images on his computer | State showed intentional placement and handling of files | Sufficiency affirmed; conviction sustained |
| Suppression/description of warrant | Warrant overly broad, items not particularized | Kramer non-binding; broader seizure not shown to harm | Warrant description sufficient; suppression not required; no reversible harm |
| Sentencing discretion under Hedden | Mandatory minimums should apply without deviation | Court may deviate per Hedden | Sentence vacated; remanded for resentencing |
Key Cases Cited
- Barton v. State, 286 Ga. App. 49 (Ga. App. 2007) (reversed for lack of knowledge evidence in cache)
- Dickerson v. State, 304 Ga. App. 762 (Ga. App. 2010) (sufficiency under Jackson v. Virginia)
- Kramer v. State, 260 Ga. App. 546 (Ga. App. 2003) (overbreadth not controlling where not shown to harm)
- McIntyre v. State, 311 Ga. App. 173 (Ga. App. 2011) (guidance on relevancy of warrants)
- Butler v. State, 130 Ga. App. 469 (Ga. App. 1973) (general description permissible when exact description impossible)
- Smith v. State, 274 Ga. App. 106 (Ga. App. 2005) (warrant descriptiveness acceptable)
- Jones v. State, 313 Ga. App. 590 (Ga. App. 2012) (overbreadth does not doom lawful searches)
- Hedden v. State, 288 Ga. 871 (Ga. 2011) (controls sentencing discretion)