McKinney v. State, 300 Ga. 562

On May 31–June 2, 2002, Shaquilla Weatherspoon disappeared; her body was found in woods near Greenbriar Mall six days later in moderate–advanced decomposition; medical examiner ruled manner homicidal but could not identify precise cause of death.
Appellant Roy McKinney reported a timeline in which Weatherspoon left for a party around 1:30 a.m.; he claimed he was locked out earlier and had been drinking that evening; he did not testify at trial.
Multiple witnesses contradicted parts of McKinney’s story (e.g., neighbor saw the couple’s car at ~1:00 a.m. with Weatherspoon slumped over), and evidence of McKinney’s prior controlling and physically abusive behavior was admitted, including threats to kill and prior battery arrest.
The couple’s rental car was found abandoned in a high-crime area; the car showed signs of break-in, a fingernail with a stain and a bloodstain on the headrest whose DNA matched a 15-year-old unrelated individual; none of the latent prints matched McKinney.
The State’s theory: McKinney, a controlling, abusive husband who had been drinking, killed Weatherspoon when she attempted to leave; the circumstantial record allowed the jury to reject alternative hypotheses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for malice murder	McKinney: evidence insufficient under former OCGA § 24‑4‑6 and Jackson v. Virginia; circumstantial gaps and forensic results (DNA/prints) point away from him	State: totality of circumstantial evidence (inconsistent statements, abuse history, last-seen evidence, body hidden) permits jurors to exclude other reasonable hypotheses	Affirmed — evidence was sufficient for a rational jury to find McKinney guilty beyond a reasonable doubt and to exclude other reasonable hypotheses
Sufficiency of evidence for cruelty to child (third‑degree)	McKinney: not raised on appeal, no separate argument	State: evidence of assaultive conduct in presence of the child supports the lesser‑included conviction	Affirmed — appellate court reviewed and found the evidence sufficient

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of evidence review: whether any rational trier of fact could find guilt beyond a reasonable doubt)
Simmons v. State, 291 Ga. 705 (2012) (jury may decide whether circumstantial evidence excludes every other reasonable hypothesis)
Benson v. State, 294 Ga. 618 (2014) (circumstantial facts — last seen alive in good health and body found hidden — support homicidal inference)
Currier v. State, 294 Ga. 392 (2014) (totality of evidence, not a single expert opinion, governs sufficiency analysis)
Vega v. State, 285 Ga. 32 (2009) (credibility determinations and resolution of conflicts are for the jury)