Lewis v. State
298 Ga. 889
| Ga. | 2016Background
- Victim Ophir Thompson was beaten and shot to death during a February 11, 2012 home invasion; multiple firearms and cash were stolen from a safe. Eyewitnesses saw Ronnie Duane Lewis enter the home armed and break a window; another eyewitness saw him inside with a rifle. Lewis had rented a second house on the property.
- Lewis and an accomplice, Mickey Mulder, bound and assaulted Thompson, forced open a safe, and shot him; Lewis later displayed the stolen money and admitted to a friend that he killed Thompson (claiming self-defense).
- Lewis gave two custodial interviews to police on February 12, 2012 (one early-morning interview of ~30 minutes that was stopped, and a second interview about 12 hours later); he signed Miranda waivers and confessed to striking Thompson repeatedly with a gun.
- Trial: indicted May 21, 2013; jury convicted on all counts (malice murder, armed robbery, burglary, false imprisonment, aggravated assault) after a November 4–7, 2013 trial; sentenced to life without parole plus consecutive terms.
- Post-trial/Jackson-Denno: Lewis moved to suppress the first two custodial statements as involuntary because he was under the influence of drugs; he also claimed ineffective assistance for counsel’s failure to request a corroboration instruction. The trial court denied relief; the Georgia Supreme Court affirmed.
Issues
| Issue | Lewis' Argument | State's Argument | Held |
|---|---|---|---|
| Admissibility of custodial statements (voluntariness/intoxication) | Statements inadmissible because Lewis was high on meth and lacked capacity to waive Miranda | Videotapes and investigator testimony show Lewis understood Miranda, knowingly waived, was coherent, and statements were voluntary | Denial of suppression affirmed; statements admissible |
| Ineffective assistance for failing to request corroboration instruction (OCGA § 24‑8‑823) | Counsel deficient for not requesting instruction that a confession must be corroborated | Even if deficient, overwhelming independent evidence of guilt means no prejudice | Claim fails for lack of prejudice; conviction stands |
| Sufficiency of the evidence / claim of self‑defense | Lewis claimed he acted in self‑defense, arguing evidence insufficient | Eyewitnesses, confession, possession/display of stolen guns/money, and other admissions support guilt | Convictions supported beyond a reasonable doubt; self‑defense rejected by jury |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of evidence)
- Roper v. State, 281 Ga. 878 (credibility and justification/self‑defense for jury to decide)
- Jones v. State, 285 Ga. 328 (intoxication does not automatically render statements inadmissible)
- Watkins v. State, 289 Ga. 359 (trial court determines admissibility under preponderance standard; appellate review described)
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance two‑prong test)
- Wright v. State, 291 Ga. 869 (standards for reviewing ineffectiveness claims)
- Landers v. State, 270 Ga. 189 (corroboration/confession principles and sufficiency context)
