Hunt v. State
288 Ga. 794
Ga.2011Background
- Hunt was convicted of malice murder, financial transaction card theft, and theft by taking for the death of Vernon Alderman in Gwinnett County, Georgia (December 18, 2002).
- Alderman was found shot dead in his locked apartment; his handgun, wallet, and keys were missing.
- Police traced Alderman’s credit/debit cards to Missouri; Hunt and another woman were registered at a Missouri hotel with Alderman’s vehicle and keys.
- Hunt was found with Alderman’s key ring, the missing card, and receipts; a gun-related bullet and Hunt’s blood were found in the Stratus’s jeans in the trunk.
- Prior to trial, Hunt challenged evidentiary rulings including Batson challenges and admission of a prior handgun theft; she also raised ineffective assistance claims concerning voir dire recording.
- Judgments were affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Batson challenge on juror selection | Hunt argues juror strike of Juror 5 was pretextual | State contends reasons were race-neutral and supported by record | No error; reasons sustained Batson showing and trial court did not abuse discretion. |
| Admission of prior handgun theft as similar transaction | Evidence lacked substantial similarity and served improper identification purpose | Similarities supported bent of mind and conduct, admissible for propensity/case strategy | Admissible; trial court did not abuse discretion. |
| Ineffective assistance for not recording voir dire | Lack of record hindered Batson review and proper appellate scrutiny | Counsel's strategic choice; no prejudice shown | No ineffective assistance; prejudice not shown. |
| Sufficiency of evidence to support convictions | Evidence of theft, card use, and murder connected Hunt to crime beyond reasonable doubt | Directed inferences and alternate explanations exist | Sufficient evidence to sustain verdicts. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of the evidence standard)
- Woolfolk v. State, 282 Ga. 139 (Ga. 2007) (requires race-neutral reasons; deferential Batson review)
- Rose v. State, 287 Ga. 238 (Ga. 2010) (Batson reasons must be concrete, race-neutral, neutrally applied)
- Williams v. State, 261 Ga. 640 (Ga. 1991) (similar-transaction admissibility standard; bent of mind)