Reddings v. State
292 Ga. 364
| Ga. | 2013Background
- Reddings was convicted of malice murder, aggravated assault, and two weapons counts tied to the 2009 stabbing death of Daisy Pearl Brown.
- The trial court denied a motion for new trial; Reddings appeals asserting error on non-merger of aggravated assault with murder and on venue denial.
- Evidence showed Brown was stabbed multiple times; blood traces and surveillance-linked items tied to Reddings to the scene.
- Reddings initially claimed he found Brown dead; he later altered his account when confronted with inconsistencies and there was blood on his clothing.
- Witnesses placed Reddings with the victim’s premises; girlfriend and coworkers described tension, abuse, and threatening statements by Reddings.
- The court affirmed in part, vacated aggravated assault and related weapons counts due to lack of a deliberate interval between nonfatal and fatal injuries.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether aggravated assault merged with malice murder | Reddings—aggravated assault included in murder under OCGA §16-1-7(a) | No deliberate interval; merger required | Aggravated assault merged; vacated related weapons count |
| Whether the trial court erred denying change of venue | Pretrial publicity and local connections tainted jury pool | No abuse of discretion; venire could decide impartially | No error; venue denial affirmed |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review for reasonable doubt)
- Coleman v. State, 286 Ga. 291 (Ga. 2009) (merger framework for included offenses)
- Montes v. State, 262 Ga. 473 (Ga. 1992) (merger when injuries occur in rapid succession)
- Grell v. State, 291 Ga. 615 (Ga. 2012) (aggravated assault merger with murder in similar facts)
- Bell v. State, 284 Ga. 790 (Ga. 2009) (merger when multiple wounds with same weapon)