Hendricks v. State
290 Ga. 238
| Ga. | 2011Background
- Hendricks was convicted of malice murder, aggravated assault, weapon offenses related to a public gathering, and firearm offenses for the January 17, 2004 shooting at a Boom Boom Room; Collier died from gunshot wounds and Fleming and Burns were non-fatally shot.
- Witnesses testified Hendricks, a club bouncer, confronted defendants during a debt-related dispute and the fight escalated in the club.
- Collier produced a pistol and fired into the air; Hendricks then shot toward Collier as Collier turned away, both exiting the club and into the parking lot where Collier died.
- Eyewitnesses observed Hendricks firing toward Collier and continuing to shoot into the crowd, supporting transferred-intent liability for the crimes against Fleming and Burns.
- Hendricks challenged various trial issues, including Brady material, sequestration, ineffective assistance of counsel, and evidentiary rulings; the trial court denied relief and the convictions stood.
- On appeal, the Georgia Supreme Court affirmed all judgments, concluding there was sufficient evidence and that no reversible error occurred in the asserted trial and post-trial rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for murder and related offenses | State | Hendricks | Evidence suffices; transferred intent supported. |
| Brady violation claim and disclosure | State | Hendricks | No Brady violation shown; disclosures not material. |
| Sequestration violation and mistrial issue | State | Hendricks | No mistrial error; record inadequate to show reversible error. |
| Effectiveness of defense counsel | State | Hendricks | Counsel’s decisions were within reasonable professional judgment; no prejudice established. |
| Exclusion of witnesses at new-trial hearing and potential Brady material | State | Hendricks | Exclusion proper; no proven Brady material arising from testimony. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court, 1979) (sufficiency review for criminal convictions)
- Culler v. State, 277 Ga. 717 (2004) (transferred intent and evidentiary conflicts)
- Tolbert v. State, 282 Ga. 254 (2007) (credibility and trial-court findings review)
- Simmons v. State, 271 Ga. 563 (1999) (standard for ineffective-assistance review and prejudice)
- Smith v. Francis, 253 Ga. 782 (1985) (prescription for evaluating trial counsel performance)