Jackson v. State
288 Ga. 213
| Ga. | 2010Background
- On March 22, 2005, Anwar Harris was shot multiple times after leaving an apartment leasing office with his girlfriend and infant.
- Elton Erwin Jackson, nicknamed 'June,' was identified by three eyewitnesses as the shooter and was later seen fleeing in a pickup truck.
- The medical examiner attributed Harris's death to gunshot wounds to the head, neck, and chest.
- Evidence showed prior financial disputes: Harris burglarized Jackson's home and stole about $50,000; a quarrel over money occurred weeks before the shooting.
- Jackson was convicted of malice murder and related offenses; the trial court sentenced him as described in the notes.
- On appeal, Jackson challenged sufficiency of the evidence and alleged multiple instances of ineffective assistance of counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Jackson argues evidence does not prove guilt beyond a reasonable doubt. | State contends three eyewitness identifications and forensic evidence prove guilt. | Evidence was sufficient; three eyewitness identifications supported guilt beyond reasonable doubt. |
| Ineffective assistance of counsel - multiple subclaims | Counsel failed in several respects, prejudicing Jackson. | Counsel's decisions were reasonable and/or the evidence of guilt was overwhelming, negating prejudice. | No reversible error; cumulative defense errors did not prejudice the outcome; trial credibility remains intact. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (establishes standard for reviewing sufficiency of evidence)
- Pruitt v. State, 282 Ga. 30 (Ga. 2007) (ineffective assistance standard applying presumption of reasonable conduct)
- Watkins v. State, 285 Ga. 107 (Ga. 2009) (applies ineffective assistance framework)
- Nash v. State, 285 Ga. 753 (Ga. 2009) (preference for admissible evidence; objective standard for defense objections)
- Dockery v. State, 287 Ga. 275 (Ga. 2010) (continuing witness rule regarding line-up affidavits not testimony)
- Green v. Georgia, 442 U.S. 95 (U.S. 1979) (necessity and trustworthiness requirements for hearsay exception)
- Belmar v. State, 279 Ga. 795 (Ga. 2005) (necessity and particularized guarantees of trustworthiness in hearsay)
- Jenkins v. State, 604 S.E.2d 789 (Ga. 2004) (confrontation clause scope and testimonial versus non-testimonial statements)
- Boyt v. State, 286 Ga.App. 460 (Ga. App. 2007) (preferred practice regarding prior consistent statements instruction)