Mattei v. State, 307 Ga. 300

On June 30, 2011, Angela Williams was shot multiple times while sitting in her car in an isolated Fairburn parking lot; she later died from a gunshot wound to the chest.
Two months earlier Mattei and Williams entered a largely secret "marriage of convenience;" Mattei added Williams to his life-insurance family rider that paid $150,000 for accidental spousal death.
Surveillance showed Williams following Mattei’s truck toward the lot shortly before the shooting; Mattei’s truck left the scene before rescue arrived.
Investigators found Mattei’s computer searches for how to obtain a death certificate, recent policy checks, and paperwork for filing a life-insurance claim; Mattei notified the insurer after obtaining a death certificate.
Prosecution witnesses: former roommate Crystal Bridges testified Mattei once proposed an insurance-fraud scheme (2009); jailhouse informant Marlon Avila testified Mattei confessed to shooting Williams three times; shell casings matched a .380 handgun.
Mattei was convicted of malice murder, aggravated assault, weapons offenses, and insurance fraud. He appealed, arguing (1) insufficient evidence and (2) erroneous admission of Bridges’s testimony under OCGA § 24-4-404(b); the Georgia Supreme Court affirmed.

Issue	Plaintiff's Argument (Mattei)	Defendant's Argument (State)	Held
Sufficiency of the evidence to sustain convictions	Evidence is insufficient; jailhouse confession and other evidence are unreliable/uncorroborated	Evidence (surveillance, insurance motive, searches, paperwork, confession, shell casings, witness testimony) permits a rational jury to convict	Affirmed — viewed in light most favorable to verdicts, evidence was sufficient under Jackson v. Virginia
Admissibility of Bridges’s testimony (other-acts under OCGA § 24-4-404(b))	Bridges’s 2009 insurance-fraud conversation was extrinsic, remote, and unfairly prejudicial; irrelevant to the charged murder	Testimony was admissible to prove motive (willingness to harm for insurance proceeds); probative value outweighed prejudice and limiting instruction mitigated risk	Affirmed — trial court did not abuse discretion; testimony was relevant to motive and not substantially more prejudicial than probative

Jackson v. Virginia, 443 U.S. 307 (establishes standard for reviewing sufficiency of evidence)
Brannon v. State, 298 Ga. 601 (sets test for admissibility of other-acts evidence under Rule 404(b))
Booth v. State, 301 Ga. 678 (admissibility governed by OCGA § 24-4-404(b) for trials after Jan 1, 2013)
Kirby v. State, 304 Ga. 472 (explains motive relevance and that overall similarity is not required for 404(b) when used to show motive)
Fleming v. State, 306 Ga. 240 (Rule 403 exclusion is extraordinary; trial court’s balancing reviewed for abuse of discretion)
Malcolm v. State, 263 Ga. 369 (vacatur of felony-murder counts by operation of law)