Rice v. State
292 Ga. 191
Ga.2012Background
- Rice murdered Connie Mincher and her 14-year-old son Ethan; burglary also charged.
- Jury recommended death sentences for both murders; trial court imposed death sentences.
- Evidence showed long-standing harassment by Rice and a motive to kill Minchers.
- Murder scenes included duct-taping victims; multiple hatchet blows; depravation indicated.
- Competency trial conducted; battle over mental state and admissibility of prior records.
- Extensive voir dire conducted; multiple jurors excused or challenged; defense and prosecution debated procedures.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Competency trial validity | State contends competency trial properly conducted. | Rice argues trial court erred in competency proceedings and related waivers. | Competency trial valid; waiver rules apply; no reversible error. |
| Juror selection and bias | Court properly evaluated potential juror bias and excusals. | Rice asserts multiple jurors were improperly qualified or excused. | No reversible error; trial court's determinations supported by record. |
| Guilt/innocence deposition admissibility | Deposition admissible under law of the case and notice rules. | Challenged confrontation rights and statutory notice; not preserved. | Law-of-the-case/waiver controls; arguments waived. |
| Continuance for sentencing mitigation | Defense needed delay to obtain mitigating evidence. | Court abused discretion by denying continuance for Dr. Cardin. | No abuse; trial court acted within discretion given cooperation and alternatives. |
| Ineffective assistance of counsel | Counsel failed to investigate and prepare mitigating evidence adequately. | Counsel acted reasonably; any deficiencies not prejudicial. | Overall performance not prejudicial; claims fail. |
Key Cases Cited
- Lance v. State, 275 Ga. 11 (Ga. 2002) (deference to trial court on juror bias; backstop standard)
- Greene v. State, 268 Ga. 47 (Ga. 1997) (burden on trial court to determine juror bias; deference standard)
- Gissendaner v. State, 272 Ga. 704 (Ga. 2000) (waiver rule in death-penalty appeals)
- Nance v. State, 272 Ga. 217 (Ga. 2000) (proper excusal of biased jurors; consciousness of harm standard)
- Rhode v. State, 274 Ga. 377 (Ga. 2001) (mitigating circumstances and jury charges; unanimity not required for mitigation)
- Braley v. State, 276 Ga. 47 (Ga. 2002) (prosecutor comments and Golden Rule concerns; prejudice standard)
- King v. State, 273 Ga. 258 (Ga. 2000) (juror willingness to consider death; personal interest exception)