Parrott v. State
318 Ga. App. 545
Ga. Ct. App.2012Background
- Parrott was convicted of one count of child molestation after a jury trial.
- Victim K. N. was 15; she slept at Parrott’s home where he was married to her biological mother.
- K. N. testified Parrott touched her breasts, rubbed her vagina, and his aroused penis touched her while she struggled.
- Parrott admitted, in later interviews, to some touching but claimed he was asleep and had parasomnia.
- The defense introduced expert testimony and a polygraph; the State sought to use polygraph information for impeachment.
- Parrott challenged the polygraph references, juror-for-cause denial, and sufficiency of the evidence for intent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Polygraph admission and impeachment scope | Parrott contends polygraph reference was improper | State argued polygraph could be used for impeachment | No reversible error; trial court did not abuse discretion |
| Juror for-cause dismissal | Juror had bias due to sister’s molestation, should have been dismissed | Juror could be impartial and listen to evidence | Court did not abuse discretion; juror remained on panel |
| Sufficiency of evidence on intent | Evidence failed to prove intent; he was asleep | Evidence supports inferred intent to arouse sexual desires | Evidence sufficient to sustain conviction; no directed verdict error |
Key Cases Cited
- Morris v. State, 264 Ga. 823 (Ga. 1995) (polygraph testimony admissibility and impeachment framework)
- Norman v. State, 278 Ga. App. 497 (Ga. App. 2006) (polygraph results admissible to explain conduct with no prejudice absent stipulation)
- Klausen v. State, 294 Ga. App. 463 (Ga. App. 2008) (credibility evaluation and sufficiency in child molestation)
- DeLong v. State, 310 Ga. App. 518 (Ga. App. 2011) (intent and circumstantial evidence in sexual conduct cases)