Jimenez v. State
294 Ga. 474
Ga.2014Background
- Jimenez attacked his wife as she opened the door on Jan. 20, 2012 and stabbed her multiple times in the presence of their three children, killing her with a kitchen knife.
- Jimenez fled the scene and surrendered to police the following day, admitting that he stabbed his wife.
- He was charged with malice murder, felony murder (aggravated assault), possession of a knife during a crime, and three counts of first-degree cruelty to children.
- A jury found Jimenez guilty on all counts after trial, and the trial court sentenced him accordingly; the felony murder conviction was vacated by operation of law.
- On appeal, Jimenez challenged the sufficiency of the evidence and raised arguments about the trial court’s handling of a motion for a new trial; the appellate court affirmed the convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the evidence legally sufficient to support the verdict? | Jimenez | State | Yes; evidence sufficed to support all convictions. |
| Did the trial court abuse discretion in denying a new-trial motion under OCGA 5-5-20/5-5-21? | Jimenez challenged thirteenth-juror weighing | State urged discretion proper | No; court acted within its broad discretion to weigh the evidence. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court, 1979) (sufficiency review requires substantial evidence)
- Brockman v. State, 292 Ga. 707 (Ga. 2013) (thirteenth juror concept in new-trial context)
- Malcolm v. State, 263 Ga. 369 (Ga. 1993) (vacatur of felony-murder conviction; guidelines for new-trial discretion)