Heidt v. State, 292 Ga. 343

Heidt was tried in Effingham County and convicted of two malice murders, aggravated assault, aggravated battery, burglary, attempt to commit arson in the first degree, and three firearm counts; appeal challenged sufficiency, conflict-disqualified counsel, judge disqualification, venue, juror rehabilitation, admissibility of prior conduct, and Brady claim.
Evidence showed Heidt had a sexual relationship with his sister-in-law Robin; after a confrontation between Robin and Heidt’s father, the killings occurred at the parents’ Springfield home with a shotgun and gasoline used; Robin later testified against Heidt while charges against her were dismissed.
There was circumstantial evidence tying Heidt to the murders (missing shotgun, boots, gas can, spare key location, bruises consistent with firing a shotgun, inquiries about police presence at the hospital, and financial plans/inheritance talk about money from parents).
The trial court admitted evidence and conducted voir dire; issues included conflicts of interest, potential bias, and rehabilitation, all central to the appeal.
The trial court’s rulings were affirmed on appeal; the judgment and sentences were upheld. Decided January 7, 2013; reconsideration denied February 4, 2013.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Heidt argues evidence fails to prove guilt beyond reasonable doubt.	State contends evidence supports verdict.	Evidence sufficient to support convictions beyond a reasonable doubt.
Conflict of interest in defense counsel	Arora’s representation of Robin created conflict and potential prejudice.	Heidt consented to dual representation; no abuse of discretion.	No abuse of discretion; disqualification proper due to material adverse conflict.
Judge disqualification	Judge biased due to prior involvement in related orders and warrants.	Bias from within the case; extra-judicial bias not shown.	No disqualification required; no reasonable question of impartiality.
Change of venue	Pretrial publicity caused inherent prejudice making a fair trial impossible.	Venue denial proper; publicity not inherently prejudicial; voir dire adequate.	No abuse of discretion; no inherent prejudice established.
Brady claim denial	State suppressed exculpatory shotgun evidence favoring Heidt.	No suppression proven; shotgun not related to murders; evidence not exculpatory.	Brady claim rejected; no suppression proved.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review requires rational link between evidence and verdict)
Wheat v. United States, 486 U.S. 153 (U.S. 1988) (conflict-of-interest limits on counsel of choice)
Gonzalez-Lopez v. United States, 548 U.S. 140 (U.S. 2006) (right to counsel of choice; waiver of conflict not always controlling)
Registe v. State, 287 Ga. 542 (Ga. 2010) (conflict-of-interest analysis; trial court discretion)
Gear v. State, 288 Ga. 500 (Ga. 2011) (pretrial publicity and change-of-venue considerations)
Edmond v. State, 283 Ga. 507 (Ga. 2008) (discretion in change of venue; standard of review)
Riley v. State, 278 Ga. 677 (Ga. 2004) (voir dire rehabilitation and preservation of error)
Birt v. State, 256 Ga. 483 (Ga. 1986) (bias and disqualification standards for judges)