Jackson v. State
310 Ga. App. 476
Ga. Ct. App.2011Background
- Jackson was convicted after a jury trial of aggravated battery, two counts of first-degree cruelty to children, second-degree cruelty to children, and possession of marijuana regarding T.M., the four-year-old son of his girlfriend.
- T.M. suffered severe burns, multiple injuries, dehydration, and infection; burns reportedly occurred while under Jackson's care in mid-November 2006, with medical treatment delayed until November 20.
- Police found Jackson asleep with a marijuana cigar and marijuana in the residence; Jackson gave a Miranda-appropriate statement admitting some abusive conduct and ownership of some marijuana.
- T.M. forensic and trial testimony, along with a burns specialist, indicated injuries were consistent with child abuse and not with Jackson’s account of events.
- The trial court admitted expert and lay testimony; the jury found Jackson committed aggravated battery, two counts of first-degree cruelty to children, second-degree cruelty to children, and possession of marijuana.
- Jackson argued insufficient evidence and ineffective assistance of counsel; the appellate court affirmed without error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Jackson | Jackson | Evidence supports verdict |
| Ineffective assistance—trial preparation | Jackson | Jackson | No deficient performance shown |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for evidentiary sufficiency review)
- Reed v. State, 285 Ga. 64 (2009) (prosecution and expert testimony standards)
- Harvey v. State, 284 Ga. 8 (2008) (expert testimony and evidentiary considerations)
- Wallace v. State, 306 Ga.App. 118 (2010) (trial evidentiary issues and review)
- Knight v. State, 242 Ga.App. 363 (2000) (trial preparation and investigation standards)
- Lacey v. State, 288 Ga. 341 (2010) (prosecutorial comments on failure to testify)
- Jennings v. State, 282 Ga. 679 (2007) (commentary on defense proof and strategy)
