Reeves v. State
294 Ga. 673
| Ga. | 2014Background
- Appellant Robert Lee Reeves, Jr. was convicted of felony murder predicated on aggravated assault by strangulation and sentenced to life imprisonment.
- Victim Crystal Morgan’s body was found July 29, 2009 on a wooded Macon path; autopsy showed strangulation signs and sexual assault indicators.
- Male DNA from the victim matched Reeves in a sexual-assault kit and in a buccal swab; no other male DNA was found.
- The State introduced similar-transaction evidence from Reeves’ 1998 guilty plea to attempted rape to show course of conduct and bent mind.
- The trial court admitted the similar-transaction evidence with limiting instructions, and the defense challenged both the sufficiency of the evidence and the admissibility of the prior offense evidence.
- The appellate court affirmed, holding the evidence sufficient to convict and that the similar-transaction evidence was properly admitted under applicable standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the conviction legally sufficient based on circumstantial evidence? | Reeves argues possible alternative theory of consensual sex and another assailant. | State contends the evidence, viewed to exclude other reasonable hypotheses, supports guilt. | Sufficient circumstantial evidence; excludes reasonable hypotheses beyond guilt. |
| Was admission of the 1998 similar transaction proper? | State showed similarity to prove motive/intent; defense argues insufficient similarity. | Trial court properly weighed similarity against risk of prejudice. | Yes; court did not abuse discretion; similarities were substantial and admissible. |
| What is the proper standard of review for admitting similar-transaction evidence? | Reed clarifies abuse-of-discretion standard for such rulings. | N/A or not asserted. | Abuse-of-discretion standard applies; findings on similarity reviewed for clear error. |
Key Cases Cited
- Owens v. State, 286 Ga. 821 (2010) (circumstantial evidence must exclude all reasonable hypotheses beyond guilt (Jackson v. Virginia context))
- White v. State, 263 Ga. 94 (1993) (circumstantial evidence must exclude every other reasonable theory to sustain conviction)
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for evaluating sufficiency of evidence in criminal cases)
- Reed v. State, 291 Ga. 10 (2012) (abuse-of-discretion standard for admitting similar-transaction evidence; scope of review clarified)