Simpson v. State, 302 Ga. 875

In February 2013, Simpson and Dunson (the mother of his child) had a relationship dispute; Dunson was pregnant with their second child.
On Feb 18, 2013, Simpson shot Dunson in the face during a confrontation; Dunson died and her fetus did not survive.
Police found blood on Simpson’s shirt, a shell casing in the victim’s car, and a 9mm gun in the yard; ballistics linked the casing to that gun.
Simpson admitted at trial that he shot Dunson but claimed the shooting was accidental.
A DeKalb County grand jury indicted Simpson for felony murder, feticide, aggravated assault (by shooting), and possession of a firearm during the commission of a felony; jury convicted on all counts and the court imposed consecutive life terms and a consecutive five-year firearm term.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by instructing the jury on a method of aggravated assault not charged in the indictment	Simpson: the jury could have convicted based on apprehension of violent injury (uncharged method) rather than the indicted shooting	State: any instructional overbreadth was cured by the court's limiting instruction that the State must prove every material allegation of the indictment beyond a reasonable doubt	The charge error, if any, was cured by the court's instruction tying verdicts to the indictment; convictions affirmed under plain-error analysis
Whether evidence was legally sufficient to support convictions (court-reviewed sua sponte)	N/A (Simpson did not challenge sufficiency)	State: evidence supported convictions	Court independently found the evidence sufficient to permit a rational trier of fact to find guilt beyond a reasonable doubt

Jackson v. Virginia, 443 U.S. 307 (legal-sufficiency standard for convictions)
Chapman v. State, 273 Ga. 865 (instruction on unindicted method of offense is error)
Williams v. Kelley, 291 Ga. 285 (limiting instruction can cure charge defect)
Green v. State, 291 Ga. 287 (plain-error review framework)
Faulks v. State, 296 Ga. 38 (applying cure by limiting instruction under similar circumstances)