Lamb v. State, 315 Ga. App. 807

Lamb was convicted of aggravated battery; the conviction was affirmed on appeal.
The incident began with a family dispute that led to Lamb allegedly attacking the victim’s mother.
The following day, Lamb and others entered a convenience store where Lamb allegedly dug into the victim’s left eye with a nail.
Witnesses supported the victim’s version; Lamb offered an alternative, claiming any nail contact was unintentional.
The jury concluded Lamb committed aggravated battery by rendering the eye useless, and the trial court denied post-trial relief.
The court held that the eye can be a “member” rendered useless and that loss of peripheral vision can establish aggravated battery even without expert testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for aggravated battery	Lamb argues evidence is insufficient	State contends evidence showed eye injury rendered useless	Evidence sufficient beyond reasonable doubt
Necessity of expert testimony for eye injury prove-up	Lamb contends expert proof required	State relies on victim’s testimony to prove loss of eyesight	No expert testimony required; victim’s testimony can suffice

Williams v. State, 262 Ga. App. 698 (2003) (eye is a member; loss of vision can prove rendered useless)
Blackman v. State, 178 Ga. App. 88 (1986) (eye as a member for aggravated battery)
Webb v. State, 228 Ga. App. 624 (1997) (loss of use may be shown by diminished function)
Christensen v. State, 245 Ga. App. 165 (2000) (no expert testimony required to prove loss of use)
Payne v. State, 273 Ga. App. 483 (2005) (blurred vision sufficient to prove rendered useless)
Taylor v. State, 178 Ga. App. 817 (1986) (precedent supporting non-expert proof of vision loss)
Jackson v. Virginia, 443 U.S. 307 () (sufficiency standard for evidence to support a verdict)
Biggins v. State, 299 Ga. App. 554 (2009) (credibility and conflicts resolved by jury)