Hinton v. State
321 Ga. App. 445
Ga. Ct. App.2013Background
- Hinton and co‑defendants were convicted of armed robbery, hijacking a motor vehicle, and two firearm offenses; other counts were merged for sentencing.
- Evidence linked the crimes to Hinton via location, vehicle ownership, and items found.
- Victim identified a tall suspect in a white shirt and described the vehicle and weapons.
- Police found the victim’s stolen phone and weapons in the Town Car and in Hinton’s possession or car.
- Hinton was arrested about 90 minutes after the crimes in the Lincoln Town Car he admitted owning; the Town Car was described by the victim as the getaway vehicle.
- There was contested suppression of evidence regarding the stop and how it was justified.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence was sufficient to convict Hinton | Hinton: circumstantial evidence fails to exclude reasonable hypotheses | Hinton: evidence excludes other hypotheses; not enough to prove guilt | Yes; evidence suffices to support guilt beyond reasonable doubt |
| Whether the stop of Hinton’s car was lawfully supported by hearsay | State relied on hearsay to justify the stop | Stop supported by reliable information; not based on hearsay | Yes; stop lawful; suppression affirmed on proper reasoning |
Key Cases Cited
- Huff v. State, 281 Ga. App. 573 (2006) (circumstantial evidence sufficiency; party to hijacking/robbery)
- Dailey v. State, 271 Ga. App. 492 (2005) (circumstantial evidence can exclude other possibilities)
- Williams v. State, 236 Ga. App. 790 (1999) (party to hijacking evidence of co‑conduct; aiding and abetting)
- Copeny v. State, 316 Ga. App. 347 (2012) (appeals of co‑defendants decided together)
- Bell v. State, 291 Ga. App. 169 (2008) (radio dispatch description sufficiency for stop; distinguish Vansant)
- Frazier v. State, 305 Ga. App. 274 (2010) (circumstantial evidence and proper inference)
- Elrod v. State, 128 Ga. App. 250 (1973) (strongly cited for circumstantial evidence framework)
