Lewis v. State
296 Ga. 259
| Ga. | 2014Background
- Victim Deonte Hudson was shot and killed on November 13, 2007, near his apartment in Bowen Homes, Atlanta; wound caused massive internal bleeding and death later that day.
- Appellant Brandon Lewis (16 at the time, nickname “Shortneck”) and three other boys confronted Hudson after he returned from buying stamps; a fight ensued and Lewis shot Hudson once and fled with the others.
- Two witnesses identified Lewis at trial: Amber Askew (eyewitness who initially lied but later identified Lewis) and Montrez Huff (one of the other boys who testified for the State after charges against him were dropped).
- Lewis gave a videotaped statement admitting he was at Bowen Homes and claiming injuries from running into a wall; he exhibited disheveled appearance and illness at school shortly after the shooting.
- Lewis was indicted on multiple counts; convicted of felony murder (based on aggravated assault), aggravated assault (merged), and possession of a firearm during the commission of a felony; sentenced to life plus five years. Trial court denied his new-trial motion; appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to support convictions | Lewis: State witnesses Askew and Huff were unreliable; their testimony should be treated as circumstantial, triggering the higher circumstantial-evidence standard | State: Eyewitness testimony is direct evidence; credibility is for the jury; evidence viewed in favor of verdict is sufficient | Court: Affirmed—testimony remained direct; under Jackson v. Virginia standard the evidence was sufficient for conviction |
| Directed verdict / new trial on weight of evidence | Lewis: Trial court erred in denying directed verdict and refusing new trial based on weight of the evidence | State: Review limited to Jackson sufficiency standard; weight-of-evidence and credibility determinations are for the trial court and jury | Court: Affirmed—review governed by Jackson; evidence was legally sufficient |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (establishes standard for reviewing sufficiency of evidence under due process)
- Vega v. State, 285 Ga. 32 (clarifies that credibility determinations are for the jury)