Smith v. State
296 Ga. 116
| Ga. | 2014Background
- Appellant Jill Adaire Smith and co-defendant Peter Delaney were at her home the night of the fatal fire; she texted Delaney to buy cheap wine to render her husband unconscious.
- Victim was intoxicated and placed to bed in the master bedroom; no candles burning when appellant left the room.
- Fire originated primarily on the left side of the bed; interior floor fires and holes indicated accelerant use; gasoline detected near the bed.
- Investigators concluded the fire was intentionally set; candling/incense theories were considered but not supported by evidence.
- Prosecution showed motive: insurance benefits to Smith, forgery attempting to change beneficiary, and evidence of an ongoing relationship with Delaney; Delaney claimed suicide as a cover story.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence for arson and malice murder | Smith asserts the State failed to prove who started the fire and that others could have caused it. | State offered accelerant evidence and motive; jury could disbelieve alternate theories. | Evidence sufficient to support verdicts |
| Failure to give accident defense instruction and effectiveness claim | Trial court erred by not instructing on accident defense; trial counsel ineffective for not objecting. | Accident defense requires admission of starting the fire by the defendant; Smith never admitted. | No error; no ineffective assistance |
| Bruton violation from Delaney statement | Delaney’s statements could implicate Smith; Bruton issue requires curative action. | Court sustained objection; trial counsel chose not to pursue further curative measures. | No reversible Bruton error |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for evidence to support a conviction)
- Sharpe v. State, 291 Ga. 148 (Ga. 2012) (standard for appellate review of sufficiency)
- Mathis v. State, 293 Ga. 35 (Ga. 2013) (accident defense requires defendant admission)
- Mangrum v. State, 285 Ga. 676 (Ga. 2009) (arc of accident defense and procedural aspects)
- Currier v. State, 294 Ga. 392 (Ga. 2014) (claims of ineffective assistance when no objection)
- Jones v. State, 280 Ga. 205 (Ga. 2005) (strategic decisions and trial remedies)
- Junior v. State, 282 Ga. 689 (Ga. 2007) (limitations on curative actions absent requests)
- Carr v. State, 259 Ga. 318 (Ga. 1989) (procedural requirements for trial objections)
- Bruton v. United States, 391 U.S. 123 (U.S. 1968) (brings concern about non-testifying co-defendant statements)
- Delaney v. State, not cited as a reporter (not applicable) (this entry reserved for context; not a formal cited case in the opinion)