Robinson v. State
309 Ga. 729
| Ga. | 2020Background
- James Robinson lived with Summer Sanchez and her four children; on Oct. 27, 2015 four-year-old Lalia Hawthorne was found unresponsive and later died of blunt-force abdominal injury.
- Three-year-old N. H. was hospitalized shortly after with bruised bowel, bite marks, and other trauma; Dr. Donna Evans (child abuse pediatrics) testified injuries were consistent with abuse and likely occurred the prior night when Sanchez was at work.
- Sanchez’s sons gave forensic interviews describing physical hits by Robinson; Sanchez testified Robinson had punched and bitten the children and had previously punched her in the stomach.
- Robinson made statements to a jailhouse informant admitting guilt and later attempted suicide; he was acquitted of malice murder but convicted of felony murder (aggravated-assault predicate), aggravated assault, and multiple counts of cruelty to children in the first degree.
- On appeal Robinson challenged sufficiency of evidence, admission of prior-act evidence (Sanchez’s leg injuries), and admission of Dr. Evans’s opinion on bite marks; the Court vacated one cruelty conviction (Count 9) as a single-transaction sentencing error and otherwise affirmed.
Issues
| Issue | Robinson's Argument | State's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to support convictions | Evidence did not exclude Sanchez as perpetrator because both adults were present the morning Lalia was found; circumstantial evidence insufficient | Robinson made a confession to a jailhouse informant; medical, forensic, and testimonial evidence supported jury verdicts | Affirmed — evidence (including confession) sufficient under Jackson standard and OCGA §24-14-6 for circumstantial proof |
| Multiple cruelty convictions for N. H. (Counts 8 and 9) | Two cruelty counts arise from the same single-transaction injuries, so cannot support separate sentences | Counts alleged distinct acts (striking and biting) and were charged separately | Vacated Count 9 — no evidence of a deliberate interval; convictions arose from a single transaction; sentencing error corrected |
| Admission of other-acts evidence (Sanchez’s prior leg injury) | Admission was improper and prejudicial under OCGA §24-4-404(b) | Evidence was offered to show motive; jury received limiting instruction; any error was harmless given other strong evidence | Assuming error, it was harmless beyond a reasonable doubt because other properly admitted evidence (including testimony of another violent incident) and compelling proof undercut prejudice |
| Admissibility of expert testimony about bite marks and whether it embraced the ultimate issue | Dr. Evans’s opinion that bite marks were intentional/aggressive invaded the jury’s role and addressed an ultimate issue | Expert testimony was within her expertise, beyond the ken of lay jurors, and did not identify Robinson as perpetrator | Affirmed — expert testimony admissible; opinion about intentional/aggressive nature was proper and did not violate OCGA §24-7-704(b) |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard governing sufficiency review under due process)
- Hayes v. State, 292 Ga. 506 (Georgia standard: view evidence in light most favorable to verdict)
- Muckle v. State, 302 Ga. 675 (confession is direct evidence, not purely circumstantial)
- Jones v. State, 302 Ga. 488 (single-transaction rule for separate convictions/sentences)
- Gomez v. State, 301 Ga. 445 (application of single-transaction sentencing principles)
- Mosby v. State, 300 Ga. 450 (admissibility limits for expert opinion and relation to new Evidence Code)
- Collum v. State, 281 Ga. 719 (medical testimony on force beyond lay knowledge)
- Wade v. State, 304 Ga. 5 (distinguishing expert opinion that injuries are nonaccidental from impermissible opinion on the accused’s mental state)
- Adkins v. State, 301 Ga. 153 (standard for harmlessness of nonconstitutional error)
- Boothe v. State, 293 Ga. 285 (assessing whether an evidentiary error likely contributed to the verdict)