Murray v. State
295 Ga. 289
| Ga. | 2014Background
- Murray convicted of malice murder and related offenses for a shooting during a drug transaction; sentenced to life without parole under OCGA § 17-10-7(b).
- Evidence included spontaneous statements by Murray to a transport officer about the incident and a witness who saw him at the hotel and heard Murray say the victim pulled a gun and Murray “did what he had to do.”
- Murray testified he acted out of fear after the victim pointed a gun, claiming self-defense and an attempt to take the gun to escape alive.
- The jury was instructed on justification and the state’s burden to disprove it; Murray moved for directed verdict at end of the State’s case, which was denied.
- Appellant challenged (1) sufficiency of the evidence on self-defense and malice murder; (2) a jury instruction that “A crime is no less punishable if committed against a bad person than if it were perpetrated against a good person”; (3) an impeachment instruction given partially orally and partially in writing; the court addressed these challenges and affirmed.
- The Georgia Supreme Court affirmed, holding sufficient evidence supports guilt, no reversible error in the challenged instructions, and no plain error in impeachment charge.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence for malice murder given self-defense claim | Murray’s self-defense evidence required the state to disprove it beyond a reasonable doubt | State failed to disprove self-defense in its case-in-chief | Sufficient evidence supported guilt; directed verdict denial upheld. |
| Validity of the “bad person” instruction under OCGA § 17-8-57 | Instruction implied Murray was a bad person due to drug deal context | Instruction correctly stated law and did not preclude self-defense | No reversible error; instruction proper when read with overall charge. |
| Impeachment instruction completeness and due process (plain error) | Incomplete oral impeachment charge violated due process in a life-without-parole case | Written impeachment charges supplemented oral instruction; no plain error | No plain error; instructions as a whole adequately informed the jury. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (sufficiency standard for federal review of a criminal conviction)
- Mangum v. State, 274 Ga. 573 (Ga. 2001) (sufficiency review aligned with Jackson v. Virginia)
- Allen v. State, 290 Ga. 743 (Ga. 2012) (review of self-defense credibility on appeal)
- Crawley v. State, 137 Ga. 777 (Ga. 1912) (predecessor on permissible jury instruction challenges)
- Jones v. State, 277 Ga. 36 (Ga. 2003) (improper influence of circumstantial evidence in charges)
- Miner v. State, 268 Ga. 67 (Ga. 1997) (adequacy of combined oral/written instructions)
- State v. Kelly, 290 Ga. 29 (Ga. 2011) (four-pronged plain-error test for trial errors)
- Terry v. State, 291 Ga. 508 (Ga. 2012) (plain-error framework application)
- Black v. State, 261 Ga. 791 (Ga. 1991) (completeness of trial impeachment instruction)