Matthews v. State, 294 Ga. 50

Appellant Jarvis Matthews was convicted of malice murder and related offenses for the August 30, 2002, shooting death of Juan Manuel Ramirez.
The State introduced, as similar transaction evidence, Matthews’s 2001 fatal shooting tied to luring victims with a fake deal and attempting to rob them, plus Matthews’s 2003 convictions.
The State sought to prove intent, course of conduct, and common scheme or plan; eyewitness testimony linked Matthews to the 2002 shooting.
The trial occurred in 2009 under the old Georgia Evidence Code; the defense challenged the admissibility of the 2001 sentencing order and the similar transaction evidence.
The trial court admitted the 2001 sentencing order and the similar transaction evidence; the defense objected to some uses and to the court’s instructions, and sought to introduce evidence implicating another person (Scruggs).
The Georgia Court of Appeals affirmed, concluding the evidence was sufficient and the challenged evidentiary rulings were, largely, within the trial court’s discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of the 2001 sentencing order	Matthews’s prior sentencing order was relevant to the 2001 shooting to prove involvement.	The order was irrelevant and improperly admitted; objection preserved or not.	Harmless error; admission not reversible.
admissibility of similar transaction evidence under Williams test	2001 shooting admissible to prove intent, course of conduct, and common scheme.	The court abused its discretion; evidence misleadingly prejudicial.	Properly admitted under three-prong Williams test.
Prosecutor's closing argument on similar transaction evidence	Prosecutor correctly argued the inferred intent and conduct from similar evidence.	Closing argument improperly urged character inference; objection forfeited.	No reversible error; argument within prosecutorial discretion.
Jury instructions on similar transaction evidence	Instructions correctly stated uses and pattern; allowed identity consideration when appropriate.	Court misstated allowed purposes by not limiting to stated ones.	Not reversible; pattern instruction supported under law at the time.
Exclusion of evidence implicating Scruggs	Evidence could implicate Scruggs and support innocence inference.	Exclusion proper; witness lacked personal knowledge or direct information from defendants.	Harmless; other strong evidence identified Matthews as shooter.

Moore v. State, 290 Ga. 805 (2012) (three-prong test for similar transaction evidence)
Williams v. State, 261 Ga. 640 (1991) (three-prong framework for admissibility)
Reed v. State, 291 Ga. 10 (2012) (review of trial court factual findings for abuse of discretion)
Looney v. State, 232 Ga. App. 828 (1998) (pattern jury instruction for similar transaction evidence)
Jordan v. State, 230 Ga. App. 560 (1998) (proper use of similar transaction evidence)
Braithwaite v. State, 275 Ga. 884 (2002) (closing argument standards and waiver)
Scott v. State, 290 Ga. 883 (2012) (prosecutor latitude in closing arguments)
McKibbins v. State, 293 Ga. 843 (2013) (ambiguous arguments and interpretation)
Robbins v. State, 277 Ga. App. 843 (2006) (harmless error considerations in admissibility rulings)
Felder v. State, 273 Ga. 844 (2001) (admissibility of similar transaction evidence under old standard)