Hughes v. State
289 Ga. 98
| Ga. | 2011Background
- Hughes killed his wife Jacqueline by driving over her with a station wagon on the night of December 10–11, 2006; she died from blunt and thermal injuries consistent with being run over.
- Hughes had a history of domestic violence and threats toward Jacqueline, including statements about her returning only in a box.
- Police found acceleration scuffs, tire tracks, and burned skin under the car, with Jacqueline's DNA on the undercarriage; Hughes admitted driving the car that night and being the only person who drove it.
- Jacqueline's body showed grease marks and abrasions consistent with being run over; the medical and physical evidence supported a homicide theory.
- Hughes was indicted March 9, 2007; after a 2008 trial, he was convicted of malice murder, felony murder, and aggravated assault, with sentencing reflecting life imprisonment for malice murder and merger of counts.
- Hughes appealed, challenging (a) denial of a continuance due to discovery timing and (b) trial counsel’s alleged ineffective assistance for not funding a DNA expert.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused discretion by denying a continuance | Hughes asserts late DNA discovery violated OCGA 17-16-4(c). | State properly disclosed DNA evidence and expert more than ten days before trial. | No abuse; disclosures were timely. |
| Whether Hughes received ineffective assistance for not hiring a DNA expert | Failure to hire a DNA expert deprived Hughes of a meaningful defense. | Attorney's strategic choice and use of a forensic expert was reasonable; no prejudice shown. | No ineffective-assistance violation. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court, 1981) (sufficiency of evidence standard)
- Collum v. State, 281 Ga. 719 (Ga. 2007) (discovery-continuance standards under OCGA)
- Dickens v. State, 280 Ga. 320 (Ga. 2006) (admissibility of forensic evidence; reasonable-probability standard in new-trial context)
- Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court, 1984) (ineffective-assistance standard; two-prong test)
- Robinson v. State, 277 Ga. 75 (Ga. 2003) (application of Strickland standards in Georgia appellate review)
- Fuller v. State, 277 Ga. 505 (Ga. 2004) (Strickland contextual guidance)