Pye v. State
322 Ga. App. 125
| Ga. Ct. App. | 2013Background
- A jury found Trent Pye guilty of rape and other crimes.
- The trial court denied Pye’s motion for new trial and he appeals.
- Pye challenges sufficiency of the evidence for the rape conviction and alleges errors in the jury charge and ineffective assistance of counsel.
- Evidence showed Pye coerced H.J. at a cemetery, with a knife, leading to sexual intercourse alleged as nonconsensual; DNA on a vaginal swab supported the State.
- Pye admitted intercourse but claimed it was consensual; H.J. delayed reporting, a credibility issue for the jury.
- The appellate court affirmed, upholding sufficiency, rejecting plain-error and ineffective-assistance challenges.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence for rape | Conflicts and inconsistencies negate proof of lack of consent. | Jury credibility resolves conflicts; lack of consent shown by victim's testimony. | Evidence sufficient for conviction |
| Plain error in jury instruction about victim testimony alone sufficing for conviction | Instruction improperly lowers burden by not buttressing with reasonable-doubt standard. | Instruction correctly states law; no plain error. | No plain error |
| Ineffective assistance of counsel based on failure to object to the charge | Failure to object to allegedly improper charge constitutes ineffective assistance. | No error in the charge; lack of objection defeats ineffectiveness claim. | No ineffective assistance |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (standard for reviewing sufficiency of evidence)
- Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (two-prong test for ineffective assistance claims)
- Laster v. State, 307 Ga. App. 142 (Ga. App. 2010) (no plain error where error overemphasizes guilt)
- Freeman v. State, 269 Ga. App. 435 (Ga. App. 2004) (un corroborated victim testimony may be sufficient)
- Coleman v. State, 317 Ga. App. 409 (Ga. App. 2012) (review of jury instructions as a whole)
- Strozier v. State, 314 Ga. App. 432 (Ga. App. 2012) (consent and force issues within credibility determinations)
- Scott v. State, 290 Ga. 883 (Ga. 2012) (contextual evaluation of jury charges and burden of proof)