Jackson v. State, 305 Ga. 614

Background

Alandis Jackson (known as “Rock”) was convicted by a DeKalb County jury of malice murder (life), multiple aggravated assaults, burglary, false imprisonment, and related offenses for the January 11, 2012 killing of Steven Lewis and attendant crimes in Lewis’s apartment.
Facts: Jackson was admitted into the apartment by occupant Paul Jones, produced a gun, shot Lewis, admitted additional accomplices, and the group ransacked the apartment and stole drugs/money; two eyewitness victims (Jones, Robinson) identified Jackson.
Procedural posture: Jackson filed a motion for new trial (amended); the trial court denied it; Jackson appealed raising sufficiency as to burglary, three challenges to jury charges (circumstantial evidence, character, prior statements), ineffective assistance for failing to preserve those objections, and a merger claim (false imprisonment with aggravated assault).
The Court reviewed sufficiency of evidence under Jackson v. Virginia and found evidence sufficient for all convictions, explaining burglary liability as based on Jackson’s role in admitting accomplices who entered without authority and committed theft and felonies.
On jury-charge claims, the Court analyzed plain-error review (failure to object at trial) and found (a) the trial court erred in refusing a requested circumstantial-evidence instruction but the error was not prejudicial; (b) character and prior-statement instructions tracked pattern charges and contained no plain error.
On ineffective-assistance and merger: the Court rejected ineffectiveness claims (no prejudice shown given strong eyewitness evidence and proper pattern charges) and held under the Blockburger/Drinkard required-evidence test that false imprisonment and aggravated assault do not merge.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of burglary evidence	Jackson: entry was with consent so no “without authority” element met	State: Jackson aided burglary by admitting accomplices who entered without authority and ransacked the premises	Evidence sufficient; Jackson was party to burglary because he admitted others who entered without authority and committed theft/felonies
Circumstantial-evidence instruction	Jackson: requested OCGA-pattern language requiring exclusion of every reasonable hypothesis; trial court refused	State: gave alternate pattern instruction; counsel did not object at trial	Trial court’s refusal was legal error but not plain error — no prejudice because strong eyewitness direct evidence
Character and prior-statement instructions	Jackson: requested additional language that good character creates reasonable doubt and that prior inconsistent statements may be substantive evidence	State: trial court used and tailored Georgia pattern instructions; no contemporaneous objection	No plain error; pattern charges were appropriate and tailored; jury was instructed to consider all testimony as evidence
Ineffective assistance / merger of false imprisonment with aggravated assault	Jackson: counsel ineffective for not preserving objections; false imprisonment should merge with aggravated assault	State: no prejudice from failure to object; under Drinkard/Blockburger the offenses require different proof	Ineffective-assistance claim fails (no prejudice). Merger claim fails: under required-evidence test the offenses are distinct and do not merge

Key Cases Cited

Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency-of-evidence standard)
Malcolm v. State, 263 Ga. 369 (merger of felony-murder/assault into malice murder discussed at trial court level)
Davis v. State, 285 Ga. 176 (circumstantial-evidence charge requirement where circumstantial evidence relied upon)
Adams v. State, 271 Ga. 485 (party liability where accomplice enters without authority supports burglary conviction)
Drinkard v. Walker, 281 Ga. 211 (adopts required-evidence/Blockburger test for merger analysis)
Blockburger v. United States, 284 U.S. 299 (required-evidence test for determining whether offenses merge)