Stanley v. State
300 Ga. 587
Ga.2017Background
- Appellant Derrick Stanley was convicted of malice murder and related offenses for the stabbing death of Doris Murray; the two had a romantic relationship and remained in contact.
- Murray’s May 5, 2008, home repair scene involved her and appellant; family and friends planned to help with items damaged by a fire.
- Witnesses described a confrontation; Murray’s daughter forced entry, found Murray in a carport room barricaded and unresponsive.
- Appellant fled in a vehicle; a knife was recovered; he claimed a knife-related struggle with Murray and Murray had defensive wounds.
- Blood-spatter analysis indicated a mobile struggle; appellant later admitted injuring himself with the knife; evidence supported a murder conviction.
- The trial court instructed the jury regarding verdict forms and counts; appellant challenged certain sequential instructions and use of the term murder; the court later denied motions for mistrial and preserved the verdicts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the verdict instructions violated Edge sequentialism | Stanley argues the instructions were sequential. | Stanley contends Edge requires sequential handling of manslaughter if provocation evidence exists. | Not plain error; instructions were not sequential as a matter of law. |
| Whether counsel provided ineffective assistance for not objecting | Counsel failed to object to alleged sequential error. | Ineffective if error existed but did not here. | No deficiency; instructions were not improper sequentially. |
| Whether denial of mistrial for use of the word murder was erroneous | Use of the term “murder” prejudiced the proceeding. | Mistrial not required; limiting instructions mitigated prejudice. | Not abuse of discretion; mistrial denied. |
| Whether the evidence was sufficient to support malice murder | Evidence shows a deliberate killing by Stanley. | Argues insufficiency or ambiguity in proof. | Evidence sufficient to support guilty verdict beyond a reasonable doubt. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for evidentiary review)
- Edge v. State, 271 Ga. 194 (Ga. 1999) (sequential instruction concerns under Edge not shown)
- White v. State, 291 Ga. 7 (Ga. 2012) (plain-error framework requirements)
- Hill v. State, 269 Ga. 23 (Ga. 1998) (non-sequential instruction analysis)
- Terry v. State, 263 Ga. 294 (Ga. 1993) (malice murder vs. voluntary manslaughter framework)
- McGill v. State, 263 Ga. 81 (Ga. 1993) (malice murder conviction impact on provocation analysis)
- Dyal v. State, 297 Ga. 184 (Ga. 2015) (ineffective-assistance considerations in trial objections)
- Hayes v. State, 279 Ga. 642 (Ga. 2005) (instruction sequencing analysis in verdict form)
- Inman v. State, 281 Ga. 67 (Ga. 2006) (harm requirement for evidentiary error)
- Dawson v. State, 300 Ga. 332 (Ga. 2016) (reversible error requires harm in addition to error)
- Stinski v. State, 286 Ga. 839 (Ga. 2010) (prohibition on overbroad use of the term ‘murder’)
- Laney v. State, 271 Ga. 194 (Ga. 1999) (prosecutor’s use of murder vs homicide)
- Wright v. State, 275 Ga. 427 (Ga. 2002) (precedent on trial evidentiary questions)