Jackson v. State, 294 Ga. 431

Jackson and another man committed two sets of crimes on the same night; armed robbery and related offenses occurred first, followed by a murder and related assaults.
Evidence showed the same AK-47 weapon was used in both incidents, with ballistics and eyewitness identification tying Jackson to both sets of crimes.
Jackson was tried in a consolidated jury trial for multiple offenses arising from these acts, resulting in convictions including murder, armed robbery, and firearm offenses.
The State sought and obtained joinder of the two offense groups into a single trial.
Jackson challenged the jury array as a non-representative cross-section and sought a competency evaluation; the court denied a continuance and proceeded to trial, and later denied a full sua sponte competency inquiry.
Post-trial, Jackson timely filed a motion for new trial, which was denied; the appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was joinder of offenses proper?	Jackson contends joinder was improper for separate incidents.	State asserts offenses were part of a continuing spree with a common weapon and overlapping circumstances.	Joinder proper due to common conduct and close temporal proximity with shared weapon.
Was the jury array a fair cross-section?	Jackson argues under-representation of African-Americans in the venire.	State argues array not defective as long as not systematically excluding a cognizable group and random from a representative pool.	No purposeful discrimination shown; array not inherently defective.
Did the trial court abuse its discretion by denying a continuance to evaluate competency?	Jackson needed a competency evaluation before trial.	Court acted within discretion based on prior health information and courtroom behavior.	No abuse of discretion; continuance properly denied.
Did the court have to sua sponte conduct a competency inquiry?	Constitutional guarantees require inquiry if evidence of incompetence appears.	Court engaged in discussion with medical staff, counsel, and defendant; no requirement to initiate sua sponte after pretrial review.	Enumeration meritless; court appropriately proceeded.

Dingler v. State, 233 Ga. 462 (Ga. 1975) (joinder if same conduct or single scheme)
Burrell v. State, 258 Ga. 841 (Ga. 1989) (joinder/severance framework multiple offenses)
Davis v. State, 279 Ga. 11 (Ga. 2005) (continuing spree supports non-mandatory severance)
Kent v. State, 245 Ga. App. 531 (Ga. App. 2000) (arrays may not be perfect cross-section; no purposeful discrimination shown)
Pruitt v. State, 279 Ga. 140 (Ga. 2005) (burden on defendant to show purposeful discrimination in array)
Fisher v. State, 317 Ga. App. 761 (Ga. App. 2012) (array challenges require showing insufficient cross-section)
Simmons v. State, 291 Ga. 705 (Ga. 2012) (continuance and competency considerations in trial timing)
Baker v. State, 250 Ga. 187 (Ga. 1982) (constitutional competency inquiry where evidence arises)
Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (sufficiency of evidence standard)