Scruggs v. State
295 Ga. 840
Ga.2014Background
- Phillip Scruggs and Elisa Davenport lived together and frequently fought; on August 18, 2009 Scruggs poured a medium petroleum distillate on Davenport, set her on fire, and burned down the apartment building; she died 11 days later.
- Victim identified Scruggs at the scene; traces of medium petroleum distillate were found on Scruggs’ clothing; Scruggs had minor burns and was arrested nearby.
- Scruggs was convicted of malice murder and related offenses; sentenced to life without parole; other counts were merged.
- The State introduced similar-transaction evidence of a 1995 incident in which Scruggs attempted to burn his sister’s house with a Molotov cocktail filled with a similar distillate (he had pleaded guilty to terroristic threats in that case).
- The trial also admitted statements by the victim to her daughter and siblings describing prior abuse under the hearsay-necessity exception; a juror who contacted a witness’s employer was removed during trial.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Scruggs) | Held |
|---|---|---|---|
| Sufficiency of evidence for malice murder | Evidence (identification, physical evidence, victim’s statements) proves guilt beyond a reasonable doubt | Evidence was insufficient to support malice murder conviction | Court: Evidence was sufficient under Jackson v. Virginia; conviction affirmed |
| Admissibility of similar-transaction evidence | 1995 Molotov incident admissible to prove intent, bent of mind, course of conduct, and identity; conviction establishes identity of actor | 1995 act differed in some respects and was therefore inadmissible | Court: Trial court did not abuse discretion; Williams test satisfied—proper purpose, identity established, sufficient similarities (relationship, anger motive, unique weapon) |
| Admissibility of victim’s out-of-court statements under necessity exception | Statements to close family were necessary (decedent) and bore particularized guarantees of trustworthiness due to close relationships and frequent communication | Statements lacked particularized guarantees of trustworthiness | Court: Trial court acted within discretion; statements admissible under Watson necessity framework |
| Removal of juror for outside contact | Prosecutor moved to remove juror after juror visited witness’s workplace; removal appropriate | Scruggs later challenged removal | Court: Scruggs joined motion to remove juror at trial and cannot now complain; removal not error |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence)
- Sharpe v. State, 291 Ga. 148 (Georgia application of Jackson sufficiency review)
- Williams v. State, 261 Ga. 640 (framework for admitting prior-crime/similar-transaction evidence)
- Leslie v. State, 292 Ga. 368 (abuse-of-discretion review for similar-transaction rulings)
- Matthews v. State, 294 Ga. 50 (use of certified conviction to establish identity for prior act)
- Moore v. State, 288 Ga. 187 (analysis of similarity between prior acts and charged crime)
- Johnson v. State, 289 Ga. 22 (focus on similarities, not differences, for admissibility)
- Watson v. State, 278 Ga. 763 (necessity hearsay exception: necessity and particularized guarantees of trustworthiness)
- Culmer v. State, 282 Ga. 330 (trial court’s discretion in trustworthiness determination)
- Jackson v. State, 284 Ga. 826 (statements to close family bear guarantees of trustworthiness)
- Norton v. State, 293 Ga. 332 (party cannot complain about relief it requested regarding juror issues)
- Malcolm v. State, 263 Ga. 369 (merger/vacatur of overlapping convictions)