Ridley v. State, 290 Ga. 798

Ridley was convicted at a second trial of malice murder, felony murder predicated on aggravated sodomy, felony murder predicated on aggravated assault, and aggravated sodomy in connection with Lansford’s death on Oct. 4, 1994.
Lansford’s body showed extensive injuries and evidence suggesting strangulation and anal assault; autopsy indicated likely death during sexual assault.
Police investigated Ridley after prior rapes of other prostitutes; Ridley admitted to rapes in 1994 but denied Lansford’s assault during questioning in 1994 and was not initially charged with Lansford’s murder.
DNA testing in 2004–2005 matched Ridley’s DNA to Lansford’s anal sample, leading to his arrest for malice murder; he later admitted sex but denied killing Lansford.
Ridley challenged numerous trial procedures, evidentiary rulings, and jury instructions; the trial court denied relief and judgment was affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Improper commenting on the evidence	Ridley contends the judge implicitly favored the State.	Ridley argues the court’s remark showed an opinion on a key issue.	No reversible error; court explained evidentiary ruling under OCGA 17-8-57.
Admissibility of Ridley’s custodial statements	Ridley’s silence rights were violated and statements should be excluded.	Ridley did not clearly invoke right to remain silent; questioning continued.	Statement properly admitted; no clear unambiguous assertion of right to silence.
Reenactment of similar transactions	State could compel Ridley to reenact the rapes to show intent/biography.	Ridley refused to reenact; no reenactment evidence submitted.	No error; no evidence presented; defense counsel did not object.
Impeachment with prior domestic dispute	Evidence of beating a wife impeaches Ridley’s testimony.	Evidence of domestic dispute should be excluded as improper similar transaction.	Admissible to impeach Ridley as to his conduct toward women; permissible under OCGA § 24-9-20(b).
Prior inconsistent statement foundation	Prosecutor’s reading of Ridley’s 1994 statement lacked proper foundation.	Ridley acquiesced in trial court’s handling; any error waived.	Admissibility upheld; any error not preserved for reversal.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (insufficient evidence standard for sufficiency review)
Redd v. State, 240 Ga. 753 (Ga. 1978) (trial judge may explain evidentiary ruling; no improper opinion)
Linson v. State, 287 Ga. 881 (Ga. 2010) (OCGA § 17-8-57 applicability to explanations to counsel)
Paslay v. State, 285 Ga. 616 (Ga. 2009) (OCGA § 17-8-57 not generally applicable to colloquies)
Klinect v. State, 269 Ga. 570 (Ga. 1998) (test for admissibility of other-acts evidence; probative value vs. prejudice)
Compton v. State, 281 Ga. 45 (Ga. 2006) (acquiescence rule; preservation of error)
Quintanilla v. State, 273 Ga. 20 (Ga. 2000) (failure to raise issue results in waiver)
Owens v. State, 248 Ga. 629 (Ga. 1981) (trial court broad discretion on relevance)
Berghuis v. Thompkins, 560 U.S. 370 (U.S. 2010) (requirement to clearly invoke right to remain silent)
Green v. State, 275 Ga. 569 (Ga. 2002) (clarity of invocation of rights; must be unequivocal)
State v. Moon, 285 Ga. 55 (Ga. 2009) (clarification of when questioning may continue)
Jones v. State, 287 Ga. 770 (Ga. 2010) (improper jury instruction; preserved by defense)