Slaughter v. State
292 Ga. 573
| Ga. | 2013Background
- Appellant Slaughter was convicted of malice murder, felony murder, aggravated assault for shooting Hall in the chest, aggravated assault for shooting Hall in the leg, and two firearm counts.
- Victim Aikeem Hall, unarmed, was shot by Slaughter during an exchange after a prior falling-out with Hall.
- Evidence linked to Hall’s chest and leg injuries, with a fatal chest wound preceding a non-fatal leg wound; weapon and fingerprint evidence tied to Slaughter.
- Slaughter admitted shooting Hall and claimed self-defense, while denying the initial shooting or refraining from further shooting.
- Trial court found Slaughter competent to stand trial; jury convicted after a bench competency proceeding.
- Court vacated Slaughter’s sentence for aggravated assault of the leg due to merger with malice murder; the other convictions and sentences remained.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the leg aggravated assault merged with malice murder | Slaughter argues separate convictions were improper. | State contends the Leg aggravated assault was independent. | Leg aggravated assault merged; need vacate leg aggravated assault sentence. |
| Admission of victim’s prior violent acts against third parties | Slaughter sought to introduce Hall’s prior violence to justify self-defense. | State contends no prima facie justification shown. | Exclusion proper; no abuse of discretion. |
| Admissibility of testimony about provocation via investigator’s testimony | Proffered testimony would show provocation by Hall. | Evidence properly excluded; harmless error if any. | Exclusion was proper; any error harmless. |
| Competency to stand trial after bench competency proceeding | Defense asserted lack of rational understanding and ability to assist counsel. | State presented expert testimony supporting competency. | Rational trier could find competence; no reversal. |
Key Cases Cited
- Sears v. State, 292 Ga. 64 (2012) (merging when fatal injury precedes non-fatal with no deliberate interval)
- Reddings v. State, 292 Ga. 364 (2013) (merging aggravated assault with malice murder in similar circumstances)
- Coleman v. State, 286 Ga. 291 (2009) (non-fatal vs fatal injury with possible independent conviction under certain intervals)
- Alvelo v. State, 290 Ga. 609 (2012) (merger when absence of deliberate interval between injuries)
- Cloud v. State, 290 Ga. 193 (2011) (admissibility of victim’s prior acts against third parties for justification)
- Hall v. Lewis, 286 Ga. 767 (2010) (OCGA confrontation requirements for prior inconsistent statements)
- Sims v. State, 279 Ga. 389 (2005) (constitutional test for competency to stand trial)
- Johnson v. State, 266 Ga. 380 (1996) (ineffective assistance/notice regarding prior violent acts issue)
- Bennett v. State, 298 Ga. App. 464 (2009) (reliance on Johnson for prima facie justification misapplied)