Pike v. State, 302 Ga. 795

On April 8–10, 2012, Matthew Pike, William Slaton, and Daniel Slaton participated in an armed robbery at Garrett Fluellen’s mobile home; two days later Pike and Slaton beat, strangled, and dumped Justin Klaffka into the Ocmulgee River; Klaffka’s body was recovered April 15.
Daniel Slaton pled guilty before trial and testified for the State; Pike and William Slaton were tried jointly; Pike convicted of malice murder and related charges and sentenced to life without parole.
Key contested trial rulings on appeal: (1) denial of severance from co-defendant Slaton, (2) admission of autopsy photographs over Rule 403 objections, (3) admission of evidence of the April 8 armed robbery under OCGA § 24‑4‑404(b), and (4) legal sufficiency of evidence including venue.
The State relied on eyewitness testimony, Daniel’s testimony, evidence of injuries consistent with strangulation and blunt force trauma, testimony locating beating at 119 Dixie Trail and body at Knowles Landing (Houston County), and related statements and conduct (burning clothes, threats).
The trial court admitted the autopsy photos as relevant to injury and cause of death and admitted the prior armed robbery evidence as motive under Rule 404(b); the court denied Pike’s severance motion.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Pike)	Held
Sufficiency of evidence & venue	Evidence (witnesses, body found in Houston County, beating location) proves elements and venue beyond a reasonable doubt	Evidence insufficient; venue not established in Houston County	Affirmed — evidence and venue sufficient to support convictions (Jackson standard)
Severance for antagonistic defenses	Joint trial appropriate; no showing of prejudice or denial of due process	Antagonistic defenses (Slaton’s alibi blaming Pike) forced Pike to defend co-defendant’s theory and caused prejudice	Affirmed — no clear showing of prejudice; mere antagonistic defenses insufficient absent demonstrable harm
Admission of autopsy photographs (Rule 403)	Photos relevant to nature, location, and extent of injuries and corroborate cause of death	Photographs gruesome, cumulative, and unfairly prejudicial	Affirmed — photos not unusually gory for autopsy evidence, probative value outweighed prejudice under Rule 403
Admission of prior armed robbery (Rule 404(b))	Prior robbery probative of motive and connected to the murder; proof that Pike committed robbery sufficient; Rule 403 balance favors admissibility	Prior-act evidence impermissibly introduced propensity evidence and was unduly prejudicial	Affirmed — 404(b) admissible for motive, Rule 403 balancing proper, and sufficient proof of prior act existed

Bulloch v. State, 293 Ga. 179 (venue may be proved by direct and circumstantial evidence)
Propst v. State, 299 Ga. 557 (venue review under sufficiency standard)
Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence)
Johnson v. State, 301 Ga. 205 (antagonistic defenses alone do not require severance absent prejudice)
Kelly v. State, 267 Ga. 252 (defendant must show clear prejudice from joint trial to require severance)
Marquez v. State, 298 Ga. 448 (same principle regarding antagonistic defenses)
Ragan v. State, 299 Ga. 828 (Rule 403 and relevance under Georgia Evidence Code)
Benton v. State, 301 Ga. 100 (Rule 403 exclusion is extraordinary remedy)
Moss v. State, 298 Ga. 613 (autopsy photos admissible to show nature of injuries)
Thompson v. State, 302 Ga. 533 (404(b) three-part test and admissibility principles)
Bradshaw v. State, 296 Ga. 650 (Rule 403 common-sense assessment of extrinsic offense circumstances)
State v. Jones, 297 Ga. 156 (Rule 403 balancing and deference to trial court)
Dixon v. State, 302 Ga. 691 (procedural posture regarding merger and sentencing)