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