Robinson v. State, 326 Ga. App. 59

Robinson was convicted after a jury trial of aggravated assault and possession of a firearm during the commission of a felony.
The incident occurred when Robinson and Tucker argued over a $5 dice bet, moved off a porch, and Robinson fired a concealed pistol after punches were thrown.
Robinson admitted to inviting a fight and firing the gun, resulting in non-fatal injuries to Tucker.
Robinson challenged the sufficiency of the evidence to disprove a self-defense justification.
Robinson challenged the custodial interrogation, arguing she did not knowingly waive her right to counsel, but the trial court admitted her statements.
The appellate court affirmed the convictions and denial of the motion for new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for justification defense	Robinson argues State failed to disprove her justification beyond a reasonable doubt	Robinson contends evidence supports reasonable belief in deadly force	No error; jury could find lack of justified deadly force beyond reasonable doubt
Knowingly, intelligently, and voluntarily waivers of counsel at custodial interrogation	Robinson argues waiver was not knowing or intelligent due to confusion	State contends totality of circumstances show waiver was knowing and voluntary	No clear error; waiver valid given Miranda warnings and conduct of interrogation

Short v. State, 234 Ga. App. 633 (Ga. App. 1998) (State bears burden to negate justification beyond reasonable doubt)
Diaz v. State, 270 Ga. 421 (Ga. 1999) (burden to disprove justification beyond a reasonable doubt)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review: rational juror could convict beyond reasonable doubt)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (Miranda warnings; right to counsel advisement)
Davis v. State, 292 Ga. App. 782 (Ga. App. 2008) (trial court credibility findings reviewed for clear error)