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Jackson v. State
310 Ga. App. 476
Ga. Ct. App.
2011
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Background

  • 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)
Read the full case

Case Details

Case Name: Jackson v. State
Court Name: Court of Appeals of Georgia
Date Published: Jul 1, 2011
Citation: 310 Ga. App. 476
Docket Number: A11A0706
Court Abbreviation: Ga. Ct. App.