Roberts v. State, 296 Ga. 719

Victim Carlnell Walker was found dead in the trunk of his car in a closed garage; death from hyperthermia after being beaten, stabbed, gagged, and bound. Body showed he had been placed alive in the trunk and could have escaped if free.
Crime-scene evidence showed a struggle, blood patterns indicating multiple assailants, hair and items piled as if to be burned, an emptied bottle of lamp oil, and a hurricane lamp globe on the floor among debris.
Roberts’s fingerprints were found on the lamp globe; no other usable prints were on the globe. Palm prints of the victim’s blood matched co-defendant Allen; Allen had a recent hand cut and Allen’s blood was found on a sock in Roberts’s apartment.
Roberts, Allen, and Walker were acquaintances from college; Walker had told others he expected a settlement payment and was nicknamed “C-Money.”
Roberts was tried alone, convicted of malice murder, kidnaping, and false imprisonment, sentenced to life plus additional consecutive terms, and appealed the denial of his amended motion for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence (fingerprints alleged sole link)	Roberts: fingerprint on lamp globe was innocent — he visited Walker often and might have touched lamp; fingerprints were only link, so State must exclude other reasonable hypotheses	State: multiple items of circumstantial and forensic evidence tied Roberts and Allen to the murder; fingerprint placement and surrounding crime-scene facts indicate prints were made during the crime	Court: Evidence sufficient — prints were not the sole link and circumstantial evidence excluded reasonable hypotheses of innocence
Ineffective assistance for failing to call Hall as witness	Roberts: Hall would have testified Roberts helped move and unpack Walker’s belongings, explaining fingerprints on lamp globe	State: trial counsel reasonably pursued other witnesses (Roberts’s brother), had no record of Hall being provided as a witness, and Hall’s own hearing testimony did not place Roberts touching the lamp	Court: No Strickland violation — counsel’s performance not shown deficient and no reasonable probability of a different outcome if Hall had testified

Rivers v. State, 271 Ga. 115 (proof required when fingerprints are sole evidence linking defendant)
Leonard v. State, 269 Ga. 867 (same principle on fingerprint-only cases)
O’Neill v. State, 285 Ga. 125 (circumstantial evidence must exclude reasonable hypotheses other than guilt)
Crawford v. State, 292 Ga. App. 463 (circumstances can support inference prints were made during commission of crimes)
Reeves v. State, 294 Ga. 673 (circumstantial evidence need not be devoid of every inference except guilt)
Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
Strickland v. Washington, 466 U.S. 668 (two-part test for ineffective assistance of counsel)
Scandrett v. State, 293 Ga. 602 (appellate review of trial court findings on counsel performance)
Miller v. State, 296 Ga. 9 (trial strategy decisions generally not deficient performance)
Allen v. State, 293 Ga. 626 (application of Strickland on prejudice and performance)