Hill v. State
297 Ga. 675
Ga.2015Background
- Hill was convicted of felony murder and related offenses for a home invasion that killed his accomplice Lavant.
- During the May 2–3, 2009 incident, Hill and Lavant robbed partygoers at a College Park apartment, subduing victims at gunpoint.
- Barner intervened, firing at Hill; Lavant fled and was later found shot, dying at a hospital.
- Hill was identified in court by Barner and Key as an assailant; Lavant’s admission to Lewis placed Hill at the scene.
- Police recovered Hill’s cell phone and other property at Lavant’s apartment and Weekes’s account corroborated Hill’s nervous behavior after the shooting.
- Appellant argued the evidence was insufficient as a matter of law, both under a federal due process standard and under the circumstantial-evidence doctrine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence suffices under Jackson v. Virginia. | Hill contends identifications were unreliable, undermining sufficiency. | State asserts credibility determinations lie with the jury; testimony viewed in light most favorable to verdicts. | Evidence sufficient to support convictions beyond reasonable doubt. |
| Whether the circumstantial-evidence standard applies given direct evidence. | Hill argues the state relied on circumstantial evidence only. | State presented direct evidence (identifications and Hill’s admission). | Circumstantial standard not needed; even if applicable, evidence supported guilt. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (due process standard for sufficiency of evidence)
- Neil v. Biggers, 409 U.S. 188 (1972) (standard for evaluating eyewitness identification)
- Reeves v. State, 288 Ga. 545 (2011) (credibility determinations reserved for jury)
- Walker v. State, 295 Ga. 688 (2014) (witness credibility and identification are jury questions)
- Vega v. State, 285 Ga. 32 (2009) (eyewitness testimony credibility; jury determines credibility)
- Lewis v. State, 296 Ga. 259 (2014) (direct evidence not converted to circumstantial by credibility)
- Clark v. State, 296 Ga. 543 (2015) (sufficiency review; circumstantial evidence adequate)