McFarlane v. State, 291 Ga. 345

McFarlane was indicted by a Henry County grand jury on four counts for the murder of Kinaya Byrd and related offenses; he was tried December 6–10, 2010 and convicted on all counts except Count 2 which was vacated by operation of law.
He was sentenced December 10, 2010 to life imprisonment on Counts 1 and 3, and five years on Count 4, with Counts 1 and 3 to be served consecutively.
The evidence showed Byrd dragged from a neighbor's yard into her home, where she was found unresponsive with a fatal throat wound; McFarlane confessed after Miranda warnings.
McFarlane testified he killed Byrd after discovering text messages indicating Byrd’s affair and that he choked her until she lost consciousness before slashing her throat.
He filed a motion for new trial, amended later, which the trial court denied; he appealed in 2012 arguing the trial transcript was incomplete because voir dire was not recorded.
The court affirmed, holding the transcript issue lacked merit and addressing sufficiency of the evidence as well as voir dire recording requirements under OCGA § 5-6-41(a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to convict	McFarlane argues the evidence was insufficient to sustain the verdicts.	The record supports a rational jury verdict beyond a reasonable doubt.	Evidence sufficient.
Voir dire transcript requirement and potential prejudice	Voir dire was not transcribed, prejudicing McFarlane.	OCGA § 5-6-41(a) does not require voir dire in all felony cases; any prejudice is unpersuasive.	Transcript not required; no reversible error.

Jackson v. Virginia, 443 U.S. 307 ((1979)) (sufficiency standard for criminal conviction)
State v. Graham, 246 Ga. 341 ((1980)) (voir dire transcript not mandatory in felony cases unless death penalty)
Owens v. State, 233 Ga. 869 ((1975)) (voir dire recording requirements in capital cases)
Primas v. State, 231 Ga. App. 861 ((1998)) (premise of unrecorded history insufficient for new trial)