Matthews v. State
311 Ga. 531
Ga.2021Background
- On April 11, 2009 Adrianne Young was found fatally stabbed in her apartment parking lot; autopsy showed multiple deep stab wounds likely inflicted by a long serrated blade.
- Surveillance showed two men attempting to use Young’s debit card at an ATM about 10:49 p.m. near Concord Road; a still from the video led police to Apartment 2406 at Concord Chase.
- On April 16 police arrested Freeman Matthews at that apartment; during a recorded custodial interview Matthews admitted hitting and stabbing Young and described post‑crime attempts to use her debit card.
- Investigators recovered four brown‑handled steak knives of the same make as the blade found on Young, Young’s debit/credit cards and other of her items in a dumpster near Matthews’s residence, and a cap matching the ATM video.
- At trial Matthews challenged (1) the sufficiency of the evidence, (2) the trial court’s exclusion of evidence implicating a third party (Robert Miller), (3) admissibility of his custodial statement (alleging police deception and brutality), and (4) ineffective assistance of counsel for failure to object to certain testimony. The Georgia Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument (Matthews) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Sufficiency of evidence for murder, knife possession, card theft, battery | Evidence was insufficient to prove Matthews committed the stabbing and related offenses | Confession, withheld crime‑scene knowledge, cell‑tower data, matching knives, victim’s cards in dumpster, and ATM video support convictions | Affirmed — evidence legally sufficient under Jackson standard |
| Exclusion of evidence implicating third‑party (Robert Miller) | Trial court wrongly barred testimony linking Miller to the crime and that Miller was the assailant | Proffered evidence only cast bare suspicion; no direct link or proof Miller committed a similar recent crime | Affirmed — exclusion proper because proffer did not raise reasonable inference of Matthews’s innocence |
| Constitutional voluntariness of custodial confession (Due Process) | Confession involuntary due to police lies and alleged physical abuse, so Fifth Amendment bars admission | Totality of circumstances shows confession was voluntary; trial court credited investigator over Matthews | Affirmed — confession voluntary under totality of circumstances (no coercion sufficient to vitiate voluntariness) |
| Statutory voluntariness under former OCGA § 24‑3‑50 (hope of benefit / fear of injury) and related claims | Investigator’s deceptive statements and alleged brutality induced confession by fear/hope of benefit, making it inadmissible under statute | Georgia law permits some deception; statutory bar targets promises of leniency or torture; no promise of benefit or proof of physical/mental torture here | Affirmed — deception not shown to be calculated to procure untrue confession or to promise leniency; no remediable fear of injury shown |
| Ineffective assistance for failure to object to hearsay / other testimony | Counsel unreasonably failed to object to multiple hearsay statements and thus prejudiced Matthews | Many statements were admissible, cumulative, or non‑hearsay; objections likely futile | Affirmed — no ineffective assistance: objections would have been meritless or non‑prejudicial |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (establishes legal‑sufficiency standard for convictions)
- Frazier v. Cupp, 394 U.S. 731 (police misrepresentations relevant but do not automatically render confession involuntary)
- Heard v. State, 295 Ga. 559 (limits on admissibility of evidence implicating another person)
- Mann v. State, 307 Ga. 696 (interpretation of statutory "slightest hope of benefit")
- Drake v. State, 296 Ga. 286 (totality‑of‑circumstances voluntariness analysis)
- Elkins v. State, 306 Ga. 351 (standards for admitting evidence pointing to third parties)
- Johnson v. State, 296 Ga. 504 (sufficiency can be affirmed despite weaknesses in eyewitness or physical evidence)
- United States v. Lall, 607 F.3d 1277 (11th Cir.) (examples of police deception bearing on voluntariness analysis)