Jackson v. State
291 Ga. 54
Ga.2012Background
- Jackson was convicted of malice murder for the beating death of Okedas McClure after receiving a counterfeit $20 bill in exchange for drugs.
- A neighbor observed Jackson on his porch with the counterfeit money and later Jackson, with a baseball bat, outside an abandoned apartment where McClure stayed.
- Witness Dorian Heard testified that he and Jackson argued with McClure; Heard left momentarily and heard a hit, then saw McClure injured and Jackson with the bat.
- McClure required brain surgery twice and died a week later from blunt force trauma; the attending neurosurgeon linked injuries to blows with a bat.
- Two years earlier, Jackson allegedly struck Thaddeus Long in the head with a hammer; Long required hospital care and staples.
- The trial court admitted the juvenile act as similar transaction evidence, applying the standard for relevance and similarity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Jackson | Jackson | Evidence supported murder beyond reasonable doubt |
| Admissibility of similar transaction evidence | State | Jackson | Trial court did not abuse discretion; evidence admissible |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (review sufficiency of evidence for criminal conviction)
- Williams v. State, 261 Ga. 640 (1991) (test for admission of independent-offense evidence)
- Edwards v. State, 282 Ga. 259 (2007) (admission of juvenile-forged prior acts upheld)
- Waugh v. State, 263 Ga. 692 (1993) (juvenile can form requisite criminal intent)
- Lee v. State, 306 Ga. App. 144 (2010) (juvenile adjudication admissibility regarding intent)
- Reed v. State, 291 Ga. 10 (2012) (standard for admitting similar transaction evidence; abuse of discretion review)