McNaughton v. State, 290 Ga. 894

McNaughton was convicted of malice murder and aggravated assault of his wife and sentenced to life in prison.
He appeals the denial of his motion for new trial, challenging admission of similar-transaction evidence and victim's statements about prior difficulties.
Crime occurred February 15, 2009 in Coweta County; the victim had a history of domestic violence by McNaughton and contemplated divorce.
The victim had written a statement about a prior abuse incident and kept photographs of injuries; she told others she planned to divorce.
On the day of the crimes, 911 was called at 7:30 p.m.; the victim was dead with blood primarily in the office; no sign of forced entry.
Defendant’s account of the day conflicted with cell-site location data and a neighbor's observation placing him near the victim's home between 2:00–3:00 p.m.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of similar transaction evidence	McNaughton contends such evidence was not sufficiently similar or timely.	McNaughton argues the evidence is too remote and prejudicial.	No abuse of discretion; evidence admissible for course of conduct and bent of mind.
Admission of Cruz-Hernandez incident as similar transaction	The stabbing of a cellmate is dissimilar due to different weapon and relationship.	Proper focus on similarities; evidence shows unprovoked attack with a sharp instrument.	Yes, the incident was sufficiently similar and admissible to show bent of mind.
Admission of victim's hearsay statements under necessity exception	Hearsay should be admitted under necessity to prove motive and relationship.	Statements were unreliable or non-necessary under the rule.	Admissible under necessity; totality of circumstances supports trustworthiness; some testimony deemed harmless error.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for criminal convictions)
Williams v. State, 261 Ga. 640 (Ga. 1991) (similar transaction evidence admissibility framework)
Hall v. State, 287 Ga. 755 (Ga. 2010) (domestic violence prior acts admissible for similar-acts analysis)
Mullins v. State, 269 Ga. 157 (Ga. 1998) (time lapse affects weight, not admissibility)
Pareja v. State, 286 Ga. 117 (Ga. 2009) (admissibility balancing for similar-transaction evidence)
Phillips v. State, 287 Ga. 560 (Ga. 2010) (similar transaction evidence; focus on similarities)
Culmer v. State, 282 Ga. 330 (Ga. 2007) (necessity exception to hearsay; totality of circumstances)
Tuff v. State, 278 Ga. 91 (Ga. 2004) (necessity exception; guarantees of trustworthiness with close confidants)
Watson v. State, 278 Ga. 763 (Ga. 2004) (necessity and admissibility considerations in non-testimonial statements)
Cawthon v. State, 289 Ga. 507 (Ga. 2011) (necessity and corroboration evaluative framework for hearsay)