Jessie v. State
294 Ga. 375
| Ga. | 2014Background
- Jessie, pregnant in 2008, had just relinquished rights to her second child who had medical needs and had been effectively abandoned.
- She feared family disapproval and concealed her pregnancy rather than reveal it.
- On December 17, 2008, she gave birth to a live baby boy in her grandmother’s house, keeping the birth secret.
- The baby was wrapped in a quilt, hidden, and later placed in a fireplace and burned.
- GBI discovered ash and bone fragments from roughly 60% of a single infant’s skeleton in the grandmother’s yard; medical staff indicated Jessie had recently given birth.
- A trial conviction followed for malice murder and concealment; life imprisonment was imposed for murder.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for malice murder and concealment | Jessie argues insufficient intent and evidence for malice murder | State asserts evidence supports intentional killing and concealment | Evidence sufficient beyond reasonable doubt |
| Ineffective assistance of counsel | Counsel failed to pursue certain charges/ objections and other strategic decisions were deficient | Counsel acted strategically and decisions were reasonable | No deficient performance; Strickland not satisfied |
| Cruel and unusual punishment | Life sentence for a 22-year-old is cruel and unusual | Life sentence is constitutional under precedent | Life sentence sustained; not cruel and unusual |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency standard for criminal evidence)
- White v. State, 287 Ga. 713 (2010) (evidence sufficiency for malice murder and intent)
- Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance of counsel)
- Wesley v. State, 286 Ga. 355 (2010) (Strickland analysis in Georgia cases)
- Green v. State, 291 Ga. 579 (2012) (presumption of reasonable performance in counsel decisions)
- Romer v. State, 293 Ga. 339 (2013) (defense strategy and performance review)
- Nelson v. State, 283 Ga. 119 (2008) (directed verdict considerations when evidence supports conviction)
- Gandy v. State, 290 Ga. 166 (2011) (life sentence under age considerations not cruel or unusual)
- Kilpatrick v. State, 276 Ga. 151 (2003) (strategy-based non-error objections)