Mathis v. State
293 Ga. 35
| Ga. | 2013Background
- Ja'mall DeCarlos Mathis appeals convictions for felony murder, aggravated battery, cruelty to a child, and battery in Ja’Mari Jones death.
- Ja’Mari Jones was born March 26, 2008; Mathis provided little support and had prior threats and an incident during pregnancy.
- Ja’Mari spent limited time with Mathis; minimal expenditures for the child (<$200) prior to death.
- Ja’Mari died September 16, 2009 from blunt force trauma to the head with additional injuries; medical evidence did not support a death from a bed fall.
- Mathis’s account of events (placing Ja’Mari on a bed, then later an injury) conflicted with others’ testimony; post-mortem conduct suggested a history of injuries.
- Trial resulted in convictions on all charged counts with life without parole for felony murder; some verdicts merged or were vacated; post-trial motions and appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of circumstantial evidence | Mathis argues evidence did not exclude other suspects | Mathis contends guilt not proven beyond reasonable doubt | Evidence authorized a reasonable doubt-free conviction |
| Involuntary manslaughter/reckless conduct instruction | Mathis sought involuntary manslaughter theory under OCGA §16-5-3(a) | No authority for reckless conduct as misdemeanor under §16-5-60; death not from that act | No reversible error; acts did not fit reckless conduct or causation; accident instruction not plain error affecting outcome |
| Accident instruction and criminal negligence term | Omission of 'criminal negligence' in accident instruction | Omission did not affect outcome; instruction still supported acquittal framework | Omission did not affect trial outcome; plain error not shown |
| Sentencing under OCGA §16-5-1(d) for murder | State timing/notice issues regarding death penalty | Life without parole authorized post-2009 amendment; no ex post facto issue | Life without parole properly authorized; no error in sentencing |
| Effective assistance of counsel | Counsel failed to cross-examine biased witness | No showing of prejudice; missing cross-examination could not yield different result | No reversible error; failure to prove prejudice |
Key Cases Cited
- Rogers v. State, 290 Ga. 18 (Ga. 2011) (circumstantial-evidence standard of review)
- Smith v. State, 280 Ga. 161 (Ga. 2006) (credibility and conflict resolution for jury)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard for due process)
- Brown v. State, 269 Ga. 67 (Ga. 1998) (causation and evidentiary standards in homicide)
- Yeager v. State, 281 Ga. 1 (Ga. 2006) (pattern jury instruction on accident and use of brackets)
- State v. Kelly, 290 Ga. 29 (Ga. 2011) (plain-error standard of review under OCGA §17-8-58(b))
- Mangrum v. State, 285 Ga. 676 (Ga. 2009) (whether an instruction on accident is warranted)
- White v. State, 291 Ga. 7 (Ga. 2012) (accident instruction sufficiency and criminal negligence)
- Felton v. State, 283 Ga. 242 (Ga. 2008) (cross-examination and prejudice considerations)