Payne v. State
289 Ga. 691
| Ga. | 2011Background
- Payne shot and killed Allen Ricks after Ricks allegedly struck Payne and the two argued at Classie McGuire's home on November 7, 1993.
- Payne fled the scene, later surrendered, and confessed to the shooting in a statement to a GBI agent.
- The State presented witnesses about the events, including Ricks fleeing after the shooting and the absence of evidence that Ricks carried a weapon.
- Payne was convicted of malice murder in 1995, with a justification defense contested at trial.
- This appeal challenges sufficiency of the evidence, delay in appeal, ineffective-assistance claims, and jury instruction on self-defense.
- The Georgia Supreme Court affirmed the conviction, concluding the evidence supported the verdict, the delay did not violate due process, trial counsel was not ineffective, and the self-defense instruction was proper.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to support malice murder | Payne | State | Evidence suffices; rational jurors could find guilt beyond reasonable doubt. |
| Due process implications of the appellate delay | Payne | State | Delay did not violate due process after balancing Chatman factors. |
| Ineffective assistance at trial related to evidence of statements | Payne | State | No reversible error; counsel's strategic decisions not shown deficient or prejudicial. |
| Adequacy of self-defense jury instruction | Payne | State | Instruction properly stated the reasonable-person standard in context; no requirement to recite all circumstances. |
Key Cases Cited
- Avila v. State, 289 Ga. 409 (Ga. 2011) (affirms standard for reviewing justification and witness credibility on appeal)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard for criminal convictions)
- Chatman v. Mancill, 280 Ga. 253 (Ga. 2006) (appellate-delay due process balancing test)
- Vermont v. Brillon, 129 S. Ct. 1283 (U.S. 2009) (recognizes defendant bears responsibility for some appellate delay based on counsel actions)
- Osborne (District Attorney’s Office for the Third Judicial District) v. Osbourne, 129 S. Ct. 2308 (U.S. 2009) (extends consideration of defendant delay and counsel responsibility in right to appeal)