Russell v. State, 295 Ga. 899

At approximately 5:00 a.m. on June 22, 2008, Victoria Renfroe and Andrea Smith were shot and killed at Renfroe's Eastwood Drive home in DeKalb County.
Russell was Renfroe's estranged husband; the couple were separated and Renfroe was pursuing a divorce.
Evidence showed Russell had been at Renfroe's home hours before the shooting; witnesses heard arguing and a door slam.
Witnesses Anjuan Smith (12) saw a man run from the house; Ariyanna Cato (7) identified the shooter’s Nike shoes, which matched Russell's footwear.
Cell phone records and texts suggested Russell’s presence at the victims' home around the time of the shooting, undermining his alibi.
There was prior evidence of domestic violence between Russell and Renfroe (2002 chokehold; 2007 incident), bearing on motive.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Russell argues the evidence fails to prove guilt beyond reasonable doubt.	State contends the evidence was sufficient to support the verdicts.	Evidence sufficient to support guilt beyond reasonable doubt.
Voluntary manslaughter instruction	Russell requests instruction on voluntary manslaughter based on provocation.	State argues no evidence supported such a charge.	No error; no evidence to support voluntary manslaughter.
Admission of evidence tying to a prior robbery	Defense sought to introduce drug-related armed robbery evidence to link to the murders.	Proffered evidence was conjectural and lacked direct nexus.	Exclusion proper; no error.
Mistrial for non-responsive statement	Non-responsive statement from Officer Wilborn warranted mistrial.	Curative instruction sufficed to address potential prejudice.	No mistrial; curative instructionsadequate.
Refresh recollection via video	Defense sought full video to refresh Ariyanna Cato’s memory.	Limitation on use was permissible.	No reversible harm; limitations did not contribute to verdict.

Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency standard for evidence)
Blake v. State, 292 Ga. 516 (2013) (requires voluntary manslaughter instruction when slight evidence exists)
Culmer v. State, 282 Ga. 330 (2007) (provocation requirement for voluntary manslaughter)
Moore v. State, S14A0988 (2014) (fighting prior to homicide not ordinarily sufficient for provocation)
Funes v. State, 289 Ga. 793 (2011) (same principle on voluntary manslaughter provocation)
Azizi v. State, 270 Ga. 709 (1999) (admissibility of evidence with direct corpus delicti connection)
Griffin v. State, 280 Ga. 683 (2006) (limits on similar acts evidence without identified suspect)
Roseberry v. State, 274 Ga. 301 (2001) (admissibility tied to factual nexus with crimes)
Rowe v. State, 276 Ga. 800 (2003) (timing of evidence weight over admissibility)
Faircloth v. State, 293 Ga. 134 (2013) (prior difficulties as motive/relationship evidence)
Bunnell v. State, 292 Ga. 253 (2013) (curative instructions to misconduct evidence)
Scruggs v. State, 273 Ga. 752 (2001) (affirming curative instruction approach)
Rivera v. State, 295 Ga. 380 (2014) (evidentiary weight vs admissibility of prior crime evidence)