Mims v. State, 310 Ga. 853

Nathan Mims and Naty Ortiz-Ramos had an abusive relationship; they broke up in March 2014 and Mims threatened to kill her.
On April 27, 2014, Mims was at Ortiz-Ramos’s apartment; her roommate awoke to screams and found Mims straddling and beating her.
The roommate saw Mims stab Ortiz-Ramos; deputies later found Ortiz-Ramos with 37 stab wounds, including wounds to the heart and lung; she died.
Mims was still at the scene, admitted stabbing her, and acknowledged he continued to hit and stab after she was incapacitated and that he could have left.
A jury convicted Mims of malice murder and possession of a knife during the commission of a crime; he was sentenced to life without parole plus a concurrent five-year term; felony murder was vacated by operation of law.
On appeal Mims argued the evidence was insufficient because he lost control and acted unconsciously/fearfully; he also made a passing request for a new competency evaluation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to support murder conviction	Mims: he was not in control, acted from panic/instinct and thus cannot be held culpable for murder	State: eyewitness, physical evidence, Mims’s admissions, and number/nature of wounds support malice murder and weapon conviction	Affirmed — under Jackson a rational juror could reject Mims’s account and find guilt beyond a reasonable doubt
Request for new competency evaluation/new trial	Mims: (in passing) asked for competency re-evaluation and new trial	State: procedural default and no factual/legal support in the record for new evaluation	Not considered — Mims did not enumerate this issue on appeal and offered no support; argument waived
Use of defendant’s testimony when disbelieved	Mims: claimed justification/self-defense or irresistible passion	State: jury may disbelieve and rely on corroboration; defendant’s testimony can be substantive evidence if disbelieved	Affirmed — defendant’s disbelieved testimony may be used as evidence where corroborative proof exists; jury could discredit Mims

Jackson v. Virginia, 443 U.S. 307 (1979) (sets federal due‑process standard for sufficiency review)
Browder v. State, 294 Ga. 188 (2013) (appellate sufficiency review examines evidence in light most favorable to verdict)
Corley v. State, 308 Ga. 321 (2020) (questions of justification are for the jury)
Anderson v. State, 248 Ga. 682 (1982) (whether provocation reduces murder to manslaughter is generally for the jury)
Daughtie v. State, 297 Ga. 261 (2015) (defendant’s testimony, if disbelieved, may be substantive evidence when corroboration exists)
Wallace v. State, 303 Ga. 34 (2018) (appellant may not expand enumerations of error on appeal)