Muhammad v. State
290 Ga. 880
| Ga. | 2012Background
- Muhammad and his wife Shelia separated in fall 2009.
- Shelia rented a nearby house; Muhammad continued living at the marital home.
- On Nov. 4, 2009, Muhammad was seen leaving with Shelia in Shelia's car toward Shelia's new residence.
- Deputies found Shelia dead from strangulation by a ribbon; DNA linked the ends to Muhammad and the middle to Shelia; Shelia's wedding ring was found in Muhammad's pocket.
- Muhammad admitted breaking a rear window and removing the ring, and claimed he acted to check on Shelia but denied intending to harm her.
- Prior domestic violence incidents and a prior romantic involvement with Alvinice Muhammad were introduced as similar transactional evidence against Muhammad.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Muhammad challenged the sufficiency. | The State showed killer’s intent and actions. | Evidence supported conviction beyond reasonable doubt. |
| Admissibility of similar transaction evidence | Prior arson was insufficiently similar. | There were clear similarities in conduct and pattern. | Court did not abuse discretion; similar transaction properly admitted. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1980) (sufficiency review standard for criminal convictions)
- Whitehead v. State, 287 Ga. 242 (2010) (admissibility of similar transaction evidence requires sufficient similarity)