Smith v. State, 299 Ga. 424

In April 2012 a two‑month‑old infant (Keymaya) was brought to hospital in cardiac arrest and died; autopsy showed multiple bruises, hemorrhages, rib and limb fractures, neck injury, and abusive closed head/neck trauma.
Appellant Deonte Smith was alone with the infant shortly before symptoms began; he admitted lifting/squeezing the baby to try to relieve constipation and gave differing accounts to medical personnel and at trial.
Smith was indicted on multiple counts and convicted by a jury of felony murder (based on child cruelty) and related offenses; he received life for felony murder.
On appeal Smith argued two evidentiary errors: (1) the prosecutor’s cross‑examination about tattoos visible when Smith displayed his arm/scars and (2) the medical examiner’s use of a baby doll as a demonstrative aid while testifying about mechanism and force.
The Supreme Court of Georgia held the trial court abused its discretion in permitting part of the tattoo questioning but found the error harmless beyond a reasonable likelihood of affecting the verdict; the court also upheld admission of the doll demonstration.

Issue	Smith's Argument	State's Argument	Held
Admissibility of cross‑examination about tattoos (relevance)	Tattoo questioning was irrelevant and prejudicial; exceeded scope of collateral display of scars.	Defense opened the door by displaying his arm/scars; limited questions about tattoos were permissible to clarify what jury saw.	Court: Some tattoo questioning was an abuse of discretion (irrelevant), but error was harmless given overwhelming evidence and tattoos arguably aided defense.
Use of baby doll demonstrative by medical examiner	Demonstration speculative, unsupported by evidence (Smith never admitted shaking), and unfairly prejudicial.	Doll is a demonstrative aid substantially similar in relevant respects; helps jurors understand mechanism/force; proper foundation laid.	Court: No abuse of discretion; expert laid foundation, qualified conditions, and limited/qualified testimony made demonstration admissible.

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency of evidence review)
United States v. Gaskell, 985 F.2d 1056 (11th Cir.) (standards for admitting experiments/demonstrations; similarity requirement)
Moore v. State, 294 Ga. 682 (Ga.) (upholding demonstrative doll in shaken‑baby case under analogous rules)
Belmar v. State, 279 Ga. 795 (Ga.) (erroneous admission of tattoo evidence held harmless)
Rivera v. State, 295 Ga. 380 (Ga.) (standard for harmless nonconstitutional evidentiary error)