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Hinton v. State
321 Ga. App. 445
Ga. Ct. App.
2013
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Background

  • 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)
Read the full case

Case Details

Case Name: Hinton v. State
Court Name: Court of Appeals of Georgia
Date Published: Mar 25, 2013
Citation: 321 Ga. App. 445
Docket Number: A12A2216
Court Abbreviation: Ga. Ct. App.