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Manzano v. State
290 Ga. 892
| Ga. | 2012
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Background

  • On Nov. 5, 2003, Claudia Rodriguez, Manzano's wife, was found dead from a gunshot wound to the head.
  • Manzano arrived at his cousin's house around the same time and stated, "take me to Cobb County" and, "I just killed Claudia."
  • Medical examiners determined the gun was pressed to the victim's head while she was asleep on her side; Manzano claimed they were playing a game and Rodriguez was awake.
  • Prior to the shooting, Manzano grew enraged with Rodriguez over her attendance at a funeral and romantic interest expressed by a former coworker.
  • Manzano had previously told his supervisor that he had a gun to kill his wife.
  • The jury convicted Manzano of felony murder and acquitted him of malice murder; the court affirmed the judgment on appeal.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether evidence supports felony murder beyond a reasonable doubt Manzano argues insufficient evidence for felony murder State contends the facts show intent to kill or engage in killing Yes; evidence sufficient for felony murder beyond reasonable doubt

Key Cases Cited

  • Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (establishes standard for sufficiency review)
  • Manzano v. State, 282 Ga. 557 (Ga. 2007) (prior malice murder acquittal does not bar felony murder retrial)
  • Holliman v. State, 257 Ga. 209 (Ga. 1987) (felony murder does not require malice)
  • Thompson v. State, 260 Ga. 820 (Ga. 1991) (reaffirms multiple murder theories and standards)
Read the full case

Case Details

Case Name: Manzano v. State
Court Name: Supreme Court of Georgia
Date Published: Apr 24, 2012
Citation: 290 Ga. 892
Docket Number: S12A0280
Court Abbreviation: Ga.