Price v. State, 305 Ga. 608

George Edward Price was convicted of malice murder for shooting his estranged wife, Jackie Price; he was sentenced to life without parole after a 2011 jury trial.
Victim had recently separated and was living at a friend’s house; no signs of forced entry or struggle; medical examiner ruled death a homicide by gunshot wounds.
Appellant’s large red van was seen near the residence the day of the killing; a child discovered the body later that afternoon.
Price gave video-recorded statements to investigators after initially offering inconsistent accounts; he ultimately admitted to the shooting, described scene details correctly, and tested positive for gunshot residue.
Trial court held a Jackson-Denno hearing and concluded Price’s statement was voluntary; Price’s motion for new trial was denied after a hearing; felony murder conviction vacated by operation of law.

Issue	Price’s Argument	State’s Argument	Held
Voluntariness of statement	Interrogator’s statements (threat to tell “the judge,” remark he wouldn’t "see the light of day") and false claim about gunshot residue rendered confession involuntary and inadmissible	Remarks were exhortations or collateral benefits; deception about residue and warnings were permissible in a noncustodial interview; totality shows voluntariness	Court held statement voluntary and admissible under Georgia law
Trial court’s denial of motion for new trial on general grounds	Order does not show the court acted as the "thirteenth juror" by weighing credibility and conflicts	A simple denial presumes the judge knew and exercised the requisite discretion; nothing in record suggests failure to apply correct standard	Court found no error; presumes judge exercised discretion
Ineffective assistance at sentencing/mitigation	Trial counsel failed to investigate or present mitigation witnesses or argument at sentencing	No proffer or evidence at the hearing identifying what additional investigation or witnesses would have shown; no demonstrated prejudice	Court rejected claim for lack of Strickland prejudice showing
Sufficiency of evidence (not raised)	(not argued)	State relied on confession, scene details, GSR, and medical testimony	Court independently found evidence sufficient under Jackson v. Virginia

Jackson v. Virginia, 443 U.S. 307 (sufficiency-of-evidence standard)
Brown v. State, 290 Ga. 865 (promise of collateral benefit vs. promise affecting charges/sentence)
Johnson v. State, 295 Ga. 421 (totality-of-circumstances voluntariness review)
Drake v. State, 296 Ga. 286 (permissibility of deceptive tactics in noncustodial interviews)
Stinski v. State, 281 Ga. 783 (police exhortations to tell the truth permissible)
Slaton v. State, 303 Ga. 651 (Strickland standard for ineffective assistance)
Strickland v. Washington, 466 U.S. 668 (two-prong ineffective-assistance test)