Moore v. State, 314 Ga. 351

In December 2010, two-year-old Ma’Kel Moore-Tompkins suffered fatal blunt-force head trauma; medical experts concluded injuries occurred between about 7:30 a.m. and 7:30 p.m. on December 8 and were non-accidental.
Ma’Kel lived with Nikita Moore and her boyfriend Reginald Johnson; both disciplined the child with a belt and the child had prior bruises and head injuries while in Moore’s care.
On the morning of Dec. 8, Johnson had Ma’Kel alone until Moore left work (noon–2:00 p.m.); Moore then had exclusive care after she returned; multiple inconsistent accounts were given about how and when injuries occurred.
Ma’Kel was unresponsive at Moore’s workplace; Moore and Johnson delayed seeking definitive emergency care (spent 30–40 minutes in the parking lot) before driving to a hospital; child later transferred to Egleston and died on Dec. 10.
A Fulton County jury convicted Moore (and Johnson) of malice murder and other counts; Moore received life with parole eligibility for malice murder; she moved for a new trial, appealed, and challenged sufficiency of circumstantial evidence.
The Supreme Court of Georgia affirmed, holding the circumstantial evidence was sufficient to exclude reasonable hypotheses other than Moore’s guilt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circumstantial evidence was sufficient under former OCGA § 24-4-6 to support Moore's malice-murder conviction by excluding every reasonable hypothesis other than her guilt	Moore: Evidence did not exclude the reasonable hypothesis that Johnson alone inflicted the fatal injury	State: Evidence (Moore’s admissions, prior injuries under her care, inconsistent statements, delays and apparent indifference) allowed the jury to reject Johnson-only hypothesis as unreasonable	Court affirmed: circumstantial evidence sufficient; jury reasonably rejected alternative hypothesis and credited evidence implicating Moore

Hayes v. State, 292 Ga. 506 (2013) (standard of review — view evidence in light most favorable to jury verdict)
Anglin v. State, 312 Ga. 503 (2021) (circumstantial-evidence rule: not every hypothesis is reasonable; jury decides reasonableness)
Graham v. State, 301 Ga. 675 (2017) (jury resolves conflicts in evidence and witness credibility)
Wilkerson v. State, 307 Ga. 574 (2019) (deference to jury on credibility and weight of evidence)
Malcolm v. State, 263 Ga. 369 (1993) (merger/vacatur principles for sentencing counts)
Dixon v. State, 302 Ga. 691 (2017) (sentencing/merger guidance)
Tyler v. State, 311 Ga. 727 (2021) (clarifies Evidence Code provision analogous to former OCGA § 24-4-6)