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Jones v. State
316 Ga. App. 442
| Ga. Ct. App. | 2012
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Background

  • Jones was convicted of family violence battery after a trial.
  • The State presented three similar-transaction incidents to show bent of mind, course of conduct, and intent.
  • The court allowed the similar-transaction evidence after a pretrial hearing with limiting instructions.
  • The incidents include January 2005 (road-rage escalation) and October 2008 (two assaults on an intimate partner).
  • Jones did not testify; the State offered evidence and photos of injuries; defense contested inconsistencies and alleged victim aggression.
  • Jones challenged both the admissibility of the similar transactions and whether the court should rule on prior-conviction impeachment before he testified; the court denied relief and the verdict stood.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Admissibility of similar transactions Jones argues insufficient similarity and prejudicial harm. State contends sufficient similarity and probative value outweighs prejudice. Trial court did not abuse; sufficient similarity; probative value not outweighed.
Pre-trial ruling on impeachment evidence Jones asserts ruling should be made before testimony to decide whether to testify. Court may reserve ruling until impeachment is sought on cross-examination. No error; court may reserve ruling; defendant aware of convictions.

Key Cases Cited

  • Hickson v. State, 308 Ga. App. 50 (2011) (similarity standard for prior acts showing bent of mind)
  • Neal v. State, 290 Ga. 563 (2012) (prejudice vs. probative value in similar-transaction evidence)
  • Brigman v. State, 282 Ga. App. 481 (2006) (domestic-violence context permits prior acts to show mindset)
  • Neal v. State, 290 Ga. 563 (2012) (reiterated standard for similar-transaction analysis)
  • Alvarez v. State, 309 Ga. App. 462 (2011) (test for admitting similar transaction evidence)
  • Willis v. State, 214 Ga. App. 479 (1994) (prior acts showing propensity in domestic-violence cases)
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Case Details

Case Name: Jones v. State
Court Name: Court of Appeals of Georgia
Date Published: Jun 27, 2012
Citation: 316 Ga. App. 442
Docket Number: A12A0326
Court Abbreviation: Ga. Ct. App.