Miller v. State, 303 Ga. 1

Tonya Miller and Cheryl Miranda were in a romantic relationship with a history of jealousy and violence; Miranda obtained a protective order in May 2004 and later served a trespass warning against Miller.
In late February 2005 Miranda’s cell phone records show movement from Tampa, FL to Forsyth County, GA; family testimony and voicemail evidence tied use of Miranda’s phone and truck to Miller and her son Jabaris in late February–early March 2005.
On March 4, 2005 Miranda’s white truck was found deliberately set on fire near Miller’s relatives’ apartment; firefighters recovered Miranda’s burned body in the truck bed.
Autopsy showed blunt and sharp force trauma (including a severed jugular) and ligature/strangulation; injuries occurred while Miranda was alive, and death was caused by blunt/sharp force trauma.
Police executed a search warrant at Miller’s sister’s home and found Miranda’s personal items, pawn receipts, credit cards, and objects (knife/letter opener, nunchaku) that could have caused the injuries among Miller’s belongings.
Procedural posture: Miller was retried in 2013, convicted of malice murder and concealing the death of another, sentenced to life plus 10 years, appealed; this opinion affirms the convictions.

Issue	Miller's Argument	State's Argument	Held
Sufficiency of circumstantial evidence to convict of malice murder and concealing death	Evidence was too circumstantial; did not exclude every other reasonable hypothesis	Circumstantial proof (prior violence, phone/truck use, possession of victim’s items, proximity) permitted conviction	Evidence sufficient; jury could find guilt beyond reasonable hypothesis
Admission of Skeens’s testimony recounting Miranda saying she fought with "Tonya" (hearsay)	Statement was inadmissible hearsay not meeting residual exception (OCGA §24-8-807)	Statement was admissible under residual exception: trustworthy, highly probative, necessary	Trial court did not abuse discretion admitting the statement under residual hearsay exception

Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence) (1979)
Neely v. State, 302 Ga. 121 (circumstantial-evidence sufficiency; exclude other reasonable hypotheses) (2017)
Tanner v. State, 301 Ga. 852 (use of residual hearsay exception is rare; standard for abuse-of-discretion review) (2017)
Smart v. State, 299 Ga. 414 (residual hearsay exception requires exceptional guarantees of trustworthiness) (2016)
Rivers v. United States, 777 F.3d 1306 (trustworthiness inquiry focuses on declarant and circumstances of the original statement) (11th Cir. 2015)
Miller v. State, 289 Ga. 854 (prior appeal addressing similar evidence and trial issues) (2011)