McKinney v. State, 300 Ga. 562

Appellant Roy McKinney was tried and convicted of malice murder of his wife, Shaquilla Weatherspoon, and cruelty to children (third-degree as a lesser included offense); he appealed only the sufficiency of the murder evidence.
Weatherspoon was last seen May 31, 2002; McKinney called 911 June 2, reported her missing; her decomposed body was found June 6 hidden in woods near Greenbriar Mall; medical examiner ruled manner homicidal but could not identify exact cause of death.
Evidence showed a history of controlling, threatening, and physical abuse by McKinney; witnesses testified Weatherspoon feared him and had attempted to leave the relationship previously; expert testimony addressed heightened danger when victims try to leave.
McKinney’s account (locked out early evening, last saw her leave ~1:30 a.m.) conflicted with witnesses placing the couple or the car in the parking lot around 1:00 a.m., and other inconsistencies in his stories and phone records.
The rental car was later found abandoned in a high‑crime area with signs of break‑in; a bloodstain in the car matched an unrelated juvenile (T.F.), and latent prints did not match McKinney; State theorized post‑abandonment break‑in explained those findings.
At retrial (2011) the jury convicted; McKinney argued under former OCGA § 24‑4‑6 and Jackson v. Virginia that the circumstantial evidence did not exclude every other reasonable hypothesis of innocence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to support malice murder conviction	State: circumstantial evidence (body hidden, homicidal manner, history of abuse, inconsistencies in defendant’s account) excludes other reasonable hypotheses	McKinney: evidence insufficient under former OCGA § 24‑4‑6 and Jackson v. Virginia; car evidence (DNA, prints) points away from him and was not tested against other men	Affirmed: jury could exclude other reasonable hypotheses; evidence sufficient for conviction

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency review under due process)
Simmons v. State, 291 Ga. 705 (jury decides whether circumstantial evidence excludes other reasonable hypotheses)
Benson v. State, 294 Ga. 618 (circumstances supporting inference of homicide where victim last seen alive in good health and later found concealed)
Currier v. State, 294 Ga. 392 (totality of evidence, not single expert opinion, governs sufficiency)
Vega v. State, 285 Ga. 32 (credibility determinations and conflict resolution are for the jury)