Jackson v. State
322 Ga. App. 196
Ga. Ct. App.2013Background
- Jackson was indicted for malice murder, felony murder, possession of a firearm during the commission of a crime, and possession of a firearm by a convicted felon.
- The jury found him guilty only of possession of a firearm during the commission of a crime as a party to the crime; the other charges were acquitted.
- The State’s case relied on jailhouse statements by a co‑inmate (Faison) and Jackson’s own statements indicating participation in the shooting.
- Jackson challenged sufficiency of the evidence, asserted inconsistent verdicts, and claimed a speedy trial violation.
- The Court affirmed, holding there was sufficient evidence to support the conviction, no due process speedy-trial violation, and no improper effect from inconsistent verdicts.
- Key evidence included Jackson’s admission to Faison and corroborating witness testimony; Powell/Milam framework governs inconsistent verdicts and party-to-a-crime theory.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to convict as party to a crime | Jackson argues insufficient proof of his role as a party to the murder. | State contends Faison’s testimony plus corroboration support party to the crime. | Sufficiency ok; substantial evidence supports party-to-crime conviction. |
| Speedy-trial rights violation | Jackson asserts a four-year pre-indictment delay violated due process. | Delay before indictment not grounds for speedy-trial violation; post-indictment six-month delay not prejudicial. | No due-process violation; delay not presumptively prejudicial; speedy-trial claim denied. |
| Inconsistent/mutually exclusive verdicts | Jackson argues verdicts are inconsistent since one conviction and one acquittal on related offenses. | Milam abolished strict rule against inconsistent verdicts; no transparent reasoning for not guilty on felon-in-possession. | No error; inconsistency allowed; conviction affirmed based on sufficiency and Powell framework. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for assessing sufficiency of evidence in criminal cases)
- Clark v. State, 319 Ga. App. 880 (Ga. App. 2013) (application of sufficiency review in Georgia appellate practice)
- Powell, 469 U.S. 57 (U.S. 1984) (abrogation of the prohibition on inconsistent verdicts in federal law)
- Milam v. State, 255 Ga. 560 (Ga. 1986) (abrogates rule against inconsistent verdicts in Georgia)
- Turner v. State, 283 Ga. 17 (Ga. 2008) (clarifies when the inconsistent-verdict rule applies)
- Roebuck v. State, 277 Ga. 200 (Ga. 2003) (delay before indictment discussed under due process standard)
- Wimberly v. State, 279 Ga. 65 (Ga. 2005) (speedy-trial attachment and balancing framework)
- Rogers v. State, 286 Ga. 387 (Ga. 2010) (speedy-trial rights when indictment occurs during incarceration)