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Parker v. State
305 Ga. 136
| Ga. | 2019
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Background

  • Defendant James Don Parker, tried by a Jones County jury, was convicted of malice murder in the February 2014 shooting death of his friend Alan Helmuth; sentenced to life.
  • Parker claimed self-defense: he testified Helmuth beat him, blocked his escape, and lunged so Parker retrieved a .22 rifle and fired two shots.
  • Physical/medical evidence and booking photos showed only minor superficial injuries to Parker and contradicted many details of his account (no extensive defensive wounds; evidence about the sequence and orientation of shots disputed).
  • Parker was convicted after a jury trial; he filed a timely motion for new trial and appeals raising instructional errors and ineffective-assistance claims.
  • The Supreme Court of Georgia affirmed, finding the evidence sufficient and rejecting claims of jury-charge error and ineffective assistance.

Issues

Issue Parker's Argument State's Argument Held
Sufficiency of the evidence Conviction not supported; his self-defense account plausible Evidence, viewed favorably to verdict, supports murder conviction Evidence sufficient under Jackson v. Virginia; conviction affirmed
Character-evidence jury instruction Pattern charge inadequate per Hobbs; failed to instruct properly on acquittal by reasonable doubt from good character Pattern instruction adequately explained how to consider character evidence Charge proper; no reversible error
"Hastening death" jury charge Charge inconsistent with self-defense doctrine and violated OCGA §17‑8‑57; judge intimated view Charge viewed with other instructions that made self-defense scope clear; Parker affirmed recharge and did not preserve objection No plain error; jury charge as a whole adequate; no indication of judge’s bias
Ineffective assistance of counsel (expert, juror strike, investigation) Trial counsel should have called crime-scene expert, struck juror with sheriff ties, and investigated witness Howell as fact witness Strategic choices were reasonable; expert testimony would not likely change outcome; juror answered impartiality and counsel reasonably declined peremptory; Howell’s testimony cumulative/easily supplied by defendant Strickland prejudice and deficiency not shown; ineffective-assistance claims fail

Key Cases Cited

  • Jackson v. Virginia, 443 U.S. 307 (sufficiency-of-evidence standard)
  • Strickland v. Washington, 466 U.S. 668 (ineffective-assistance two-prong test)
  • Kimmelman v. Morrison, 477 U.S. 365 (premise on counsel investigation and expert testimony)
  • Hobbs, 288 Ga. 551 (discussed regarding character-instruction requirements)
  • Williams v. State, 304 Ga. 455 (pattern character charge adequate)
  • DuBose v. State, 299 Ga. 652 (plain-error standard for jury instructions)
  • Gadson v. State, 303 Ga. 871 (evaluate jury charge as whole)
Read the full case

Case Details

Case Name: Parker v. State
Court Name: Supreme Court of Georgia
Date Published: Jan 22, 2019
Citation: 305 Ga. 136
Docket Number: S18A1589
Court Abbreviation: Ga.