Smith v. State, 304 Ga. 752

In Dec. 2013 police responded after Jonathan Michael Smith (age 34) called 911 reporting his girlfriend, 16-year-old Cheyenne Hair, unresponsive; she later died of blunt-force head trauma and was eight weeks pregnant with Smith’s child.
Officers found hasps on interior and exterior doors, glued-shut windows, padlocks and keys inside the house, and containers of epoxy; Smith admitted modifying the residence but said not to detain Hair.
A hidden cellphone contained photos of a battered Hair (some with duct tape over her mouth) and timestamps close to Smith’s 911 call; texts from Smith to Hair’s mother suggested he prevented another man from entering the house.
While in pretrial detention Smith told inmates he kept Hair locked in the house and described violent sexual conduct that he said caused her death; prior-acts evidence of Smith’s restraint, abuse, and rape of other women was admitted under OCGA § 24-4-404(b).
Smith was indicted on multiple counts (including murder, feticide, cruelty to children, sexual exploitation, family violence battery, and false imprisonment); a jury convicted him on all counts and the trial court imposed life without parole plus additional consecutive terms.

Issue	Smith's Argument	State's Argument	Held
Sufficiency of evidence for false imprisonment conviction	Evidence was insufficient; Smith sought directed verdict on false imprisonment	Evidence showed confinement by locks/hasps/glued windows, texts and his admissions to cellmate — sufficient for jury submission	Affirmed: a rational juror could find false imprisonment beyond a reasonable doubt
Sufficiency of evidence for other convictions (murder, feticide, child cruelty, sexual exploitation, etc.)	(raised only as to false imprisonment) Smith contested facts at trial (claimed accidental death/consensual rough sex)	State relied on physical injuries, photos, prior-acts testimony, statements and forensic evidence to prove guilt	Court conducted routine review and found evidence sufficient to support remaining convictions

Hester v. State, 282 Ga. 239 (review standard for directed verdict/sufficiency)
Jackson v. Virginia, 443 U.S. 307 (constitutional standard for reviewing sufficiency of the evidence)
Hayes v. State, 292 Ga. 506 (deference to jury on credibility/weight of evidence)
Thomas v. State, 300 Ga. 433 (application of Jackson standard in Georgia)
Moore v. State, 340 Ga. App. 151 (false imprisonment: detention of brief duration can suffice)
Taylor v. State, 344 Ga. App. 122 (jury decides whether detention constitutes false imprisonment)
Pierre v. State, 330 Ga. App. 782 (false imprisonment conviction support where confinement evidence exists)
Metts v. State, 297 Ga. App. 330 (confinement and related sufficiency principles)