Milinavicius v. State, 290 Ga. 374

Police found two victims shot dead at appellant Milinavicius's business in East Point, Georgia; one victim had eight additional gunshot wounds.
Surveillance video showed Milinavicius entering with the victims but only Milinavicius exiting, then him taking Contreras’s vehicle and later camping near Lake Lanier.
Milinavicius told a friend he had ‘done it’ after shootings; he turned himself in two days later.
Milinavicius claimed self-defense at trial, alleging Simokaitis shot at him first and Milinavicius seized the gun and shot in defense during an attack with a chair.
Evidence included debt issues and recent requests for money from Milinavicius by the victims; Russian-English translator was provided at trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence	State	Milinavicius	Evidence sufficient for guilt beyond reasonable doubt
Miranda waiver voluntariness	State	Milinavicius	Trial court properly admitted statements; waiver voluntary under totality of circumstances
Presence at juror discussion	State	Milinavicius	Presumption of regularity; no reversible error from absence during discussion
Jury instruction on justification	State	Milinavicius	Omission to add ‘forcible felony’ did not render charge erroneous

Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court, 1979) (standard for sufficiency of evidence review)
Pineda v. State, 287 Ga. App. 200 (Ga. App. 2007) (totality of circumstances in Miranda waiver analysis)
Nguyen v. State, 273 Ga. 389 (Ga. 2001) (appellate review of trial court’s factual credibility findings)
Tate v. State, 264 Ga. 53 (Ga. 1994) (trial court credibility and standard of review for waivers)
Beck v. State, 211 Ga. App. 125 (Ga. App. 1993) (charge on justification affirmed despite omission)
Bennett v. State, 265 Ga. 38 (Ga. 1995) (clarity of jury instructions in justification defenses)
Westmoreland v. State, 287 Ga. 688 (Ga. 2010) (presumptions of regularity in trial proceedings)