Scott v. State, 307 Ga. 37

Defendant Corduray Keith Scott was convicted of felony murder and second-degree cruelty to children for the death of his 3‑month‑old son; sentenced to life without parole plus ten years.
On Jan. 18, 2010 the infant was found unresponsive after Scott had been the sole caregiver; at hospital he had seizures, severe brain swelling, and retinal hemorrhages and was later taken off life support.
Autopsy showed blunt‑force head trauma, a small skull fracture, retinal and neck hemorrhages consistent with violent shaking, and fatal injuries that occurred within hours of hospital admission.
Autopsy also revealed older injuries (nine rib fractures at varying stages of healing, a liver laceration, old lung bleeding) that medical experts testified indicated chronic, non‑accidental abuse.
Scott was interviewed twice by police (waived Miranda at first; was reminded of rights before the second interview according to the officer). In the second, Scott described prior injuries, demonstrated “rough” handling with a doll, and admitted leaving the infant facedown on a couch 10–15 minutes.
On appeal Scott challenged (1) sufficiency of the evidence (accident theory; expert uncertainty) and (2) admission of statements from the second interview for alleged Miranda defects; the Georgia Supreme Court affirmed.

Issue	Scott's Argument	State's Argument	Held
Sufficiency of evidence for felony murder and cruelty convictions	Evidence insufficient to prove non‑accidental conduct or causation; injuries could be accidental (swing fall); experts could not pinpoint mechanism	Medical and forensic evidence placed fatal injury during Scott’s custodial period; chronic injuries and Scott’s admissions/demonstration support non‑accidental abuse and reckless conduct	Affirmed — viewed favorably to jury, a rational trier of fact could find guilt beyond reasonable doubt
Admissibility of statements from second custodial interview (Miranda)	Second interview lacked renewed full Miranda warnings so statements should be suppressed	Scott was initially properly warned and waived; officer reminded rights before second interview; no requirement to repeat warnings for a continuing interrogation	Affirmed — no Miranda violation; trial court credited officer and deemed statements voluntary
Whether leaving infant unattended supports second‑degree cruelty (criminal negligence)	Brief absence does not necessarily rise to criminal negligence; dispute whether child was actually unsupervised	Leaving a very young, unsecured infant in couch corner for 10–15 minutes created obvious smothering risk; jury could find reckless disregard given prior incidents and chronic injuries	Affirmed — evidence supported criminal negligence and conviction

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency‑of‑evidence review)
Smith v. State, 304 Ga. 752 (2018) (application of Jackson standard)
State v. Cash, 302 Ga. 587 (2017) (credibility and weight of evidence for jury)
Gomez v. State, 301 Ga. 445 (2017) (jury may reject accidental‑injury hypothesis)
Ellis v. State, 299 Ga. 645 (2016) (no requirement to continually remind defendant of Miranda once waived)
Walker v. State, 296 Ga. 161 (2014) (no duty to repeat warnings for a follow‑up interview that is part of continuing interrogation)
Corvi v. State, 296 Ga. 557 (2015) (examples where leaving children unattended did not constitute criminal negligence)
Daniels v. State, 264 Ga. 460 (1994) (definition and scope of criminal negligence)
Butler v. State, 292 Ga. 400 (2013) (trial court’s factual findings on voluntariness and credibility reviewed for clear error)
Hines v. State, 254 Ga. 386 (1985) (jury may believe parts of witness testimony and disbelieve others)