Leslie v. State, 292 Ga. 368

Appellant Sajid Fitzgerald Leslie was convicted of malice murder, felony murder, and arson for the death of Lori Hastings; felony murder count was vacated by operation of law; sentence: life plus twenty years.
Date and location: April 22, 1999, in a Richmond County parking lot adjacent to a mall where Hastings’ car was found engulfed in flames with a burned body inside.
Forensic and investigative facts: Hastings died from soot inhalation and thermal burns; gasoline detected on victim’s clothing and vehicle components; victim alive when fire began; car fire set intentionally with gasoline as accelerant; carburetor backfire not shown in appellant’s vehicle.
Prosecution connected appellant to Hastings due to dating relationship and timing; first interview showed facial burns and discolored skin on appellant, with explanations that did not align with other witnesses.
Defense position: appellant testified he was at a dog fight and could not corroborate his alibi; the jury heard competing explanations about the injuries and alibi; multiple witnesses provided competing accounts regarding communications and events that night.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of similar-transaction evidence	Evidence showed bent mind toward violent acts with intimate partners; probative of intent/conduct.	Such evidence was improper and more prejudicial than probative.	Trial court did not abuse discretion; evidence admissible to show bent of mind and course of conduct.
Admission of alias-pager testimony	Pager purchase under alias was probative beyond character inference.	Testimony improperly suggested criminal propensity; not preserved.	Issue not preserved for review; no reversal.
Impeachment with prior bad acts of ex-husband	Ex-husband's prior battery offense admissible to impeach reliability.	The conviction did not involve dishonesty; improper to admit.	Ex-husband’s prior conviction inadmissible absent dishonesty; harmless error due to other evidence.
Miranda warnings and custodial interrogation	First statement should have been Miranda-warned due to custody concerns.	Interrogation occurred outside custody; warnings not required.	First interview was non-custodial; no Miranda error; custody not established.
Delay in ruling on motion for new trial	Appellant suffered due process prejudice from appellate delay.	Delay did not prejudice due to lack of specific evidence of prejudice.	Appellant failed to demonstrate specific prejudice; due process not violated.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for evidence)
Sosniak v. State, 287 Ga. 279 (Ga. 2010) (custody and Miranda guidance standard at interrogation)
Anguiano v. State, 313 Ga. App. 449 (Ga. App. 2011) (custody determination and future arrest intent)
Holloman v. State, 291 Ga. 338 (Ga. 2012) (similar-transaction evidence; abuse of discretion review)
Hall v. State, 287 Ga. 755 (Ga. 2010) (domestic-violence context for similar-transaction evidence)
Neal v. State, 290 Ga. 563 (Ga. 2012) (similar-transaction and probative value standards)
Curry v. State, 291 Ga. 446 (Ga. 2012) (limits on evidence admissibility and conjectural inferences)
Jackson v. Denno, 378 U.S. 368 (U.S. 1964) (pretrial admissibility and voluntariness of decisions)