Johnson v. State
295 Ga. 421
| Ga. | 2014Background
- Johnson was convicted in Georgia for two felony murders and related offenses arising from 2009 beatings of Crawford and McCaskill, with additional counts for aggravated assault, robbery, and armed robbery.
- Crawford was beaten on August 29, 2009; he died 12 days later from blunt force head trauma; evidence tied Johnson to the crime through brass knuckles and footprints.
- McCaskill was attacked on September 4, 2009; he suffered anoxic brain injury and died after months in a vegetative state; evidence tied Johnson to the attack through linked items and eyewitnesses.
- Detectives found brass knuckles with blood matching McCaskill and shoes matching Crawford’s footprint at Johnson’s aunt’s house; Johnson later confessed in a videotaped interview.
- Johnson was denied a new trial; on appeal the Georgia Supreme Court vacated Counts 2 and 5 for improper merger, but affirmed the remaining convictions and sentences on other counts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for felony murder and causation | Johnson argues death causation not proven beyond a reasonable doubt | State contends violent attacks were proximate cause of death | Sufficient evidence for proximate causation established |
| Voluntariness of Johnson's confession | Confession induced by hope of benefit (improper) | Confession voluntary; no improper motive | Confession voluntary and properly admitted |
| Ineffective assistance of counsel | Counsel deficient in several trial decisions | No prejudice from alleged deficiencies; strategy reasonable | No deficient performance or prejudice shown |
| Merger of Counts 2 and 5 into corresponding felony murders | Counts 2 and 5 should merge with Counts 1 and 4 | Counts 2 and 5 vacated due to improper merger |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for reviewing evidence)
- Foster v. State, 283 Ga. 484 (Ga. 2008) (voluntariness of confessions; totality of circumstances)
- Vergara v. State, 283 Ga. 175 (Ga. 2008) (voluntariness; new Georgia Evidence Code context)
- Wilson v. State, 293 Ga. 508 (Ga. 2013) (de novo review of admissibility when record undisputed)
- Preston v. State, 282 Ga. 210 (Ga. 2007) (penalties and seriousness of murder not implied promise of benefit)
- Sosniak v. State, 287 Ga. 279 (Ga. 2010) (statements about murder case context; not improper benefit)
- Pittman v. State, 277 Ga. 475 (Ga. 2004) (officer's suggestions do not constitute improper benefit)
- Mangrum v. State, 285 Ga. 676 (Ga. 2009) (exhortations to tell the truth not improper benefit)
- Canty v. State, 286 Ga. 608 (Ga. 2010) (confession induced by plea for shorter sentence—multiple charges)
- DeYoung v. State, 268 Ga. 780 (Ga. 1997) (deception by officers does not render confession involuntary)
- Jackson v. Denno, 378 U.S. 368 (U.S. 1964) (pretrial determination of voluntariness review under Denno)