Jackson v. the State
334 Ga. App. 469
Ga. Ct. App.2015Background
- Defendant Alexander Lorenzo Jackson (age 17 at time) was convicted of rape and false imprisonment for forcing sexual intercourse on S.T., a 17‑year‑old, after following her into a bathroom, locking the door, covering her mouth and holding her there.
- Victim S.T. testified; cousin T.B. attempted to intervene and alerted relatives; relatives told homeowner and police; homeowner made Jackson leave and a relative reported to police.
- Jackson gave a videotaped/audible statement to police the same day admitting partial penetration and some coercive conduct but claiming he believed S.T. consented during the act; he also called the victim’s mother and later admitted wrongdoing.
- At the custodial interview Jackson was Mirandized, was accompanied in the station by family separated by a partition, requested to speak with his step‑father (which he later did during a short break), and signed a waiver form; portions of the interrogation were played at trial twice.
- Post‑trial, Jackson moved for a new trial and raised sufficiency, voluntariness of the statement, denial of a juvenile‑waiver jury instruction, improper replay of the recording, and violation of the witness sequestration rule by allowing the investigating agent to remain in the courtroom.
- The trial court admitted the statement; the court of appeals affirmed the convictions, finding the evidence sufficient and trial errors (sequestration exception) harmless given the overwhelming evidence.
Issues
| Issue | Jackson's Argument | State's Argument | Held |
|---|---|---|---|
| Admissibility of custodial statement | Statement involuntary because Jackson was 17 and asked to speak with step‑father before waiver (J.D.B. factor requires weight) | Jackson was Mirandized, understood rights, waived voluntarily after brief family contact; totality of circumstances supports voluntariness | Court upheld admission; no clear error in voluntariness finding |
| Request for juvenile‑specific waiver jury instruction | Court should have instructed jury on factors for knowing, intelligent waiver by a juvenile | General voluntariness and waiver instructions sufficiently covered the law; age not dispositive; evidence showed voluntariness | No reversible error in denying the juvenile‑specific instruction |
| Sufficiency of evidence | Evidence insufficient—no scientific corroboration; victim’s testimony delayed and inconsistent | Victim’s testimony and Jackson’s own admissions constitute competent evidence | Victim’s testimony alone sufficient; verdict affirmed |
| Sequestration (investigating officer in courtroom) | Allowing agent to remain violated rule and deprived Jackson of right to exclude witnesses | Trial court may permit investigative officer to assist prosecution; discretion to except rule | Court found it was error to allow agent to remain without a stated need, but error was harmless given overwhelming evidence |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for evaluating sufficiency of evidence in criminal cases)
- J.D.B. v. North Carolina, 564 U.S. 261 (age may be relevant in custody/Miranda analysis)
- Miranda v. Arizona, 384 U.S. 436 (Miranda warnings and waiver requirements)
- Jackson v. Denno, 378 U.S. 368 (trial court’s responsibility to determine voluntariness of confessions)
- Bunnell v. State, 292 Ga. 253 (Georgia standard of review for admissibility of statements)
- Glass v. State, 289 Ga. 542 (harmless error doctrine where evidence is overwhelming)