State v. Hamilton
299 Ga. 667
| Ga. | 2016Background
- In October 2010, Marlina Hamilton shot her ex-husband, Christopher Donaldson, after a history of domestic violence; Donaldson later died from his wounds. Hamilton testified she acted in self-defense and described repeated prior abuse.
- Police had been called the night of the shooting; Donaldson briefly left but returned and a physical altercation ensued in which Hamilton shot him and he later died. Forensic testimony described two bullet trajectories.
- A jury acquitted Hamilton of malice murder but convicted her of felony murder (based on aggravated assault), aggravated assault–family violence, aggravated assault with a deadly weapon, and possession of a firearm during the commission of a felony; she was sentenced to life plus five years.
- Hamilton moved for a new trial alleging (1) the general grounds (verdict against weight of evidence/principles of justice) and (2) ineffective assistance of counsel (failure to seek pretrial self-defense immunity ruling, failure to call certain witnesses, failure to object to impeachment and prejudicial evidence).
- The trial court granted a new trial on the general grounds and found several instances of ineffective assistance; the State appealed. The Supreme Court of Georgia affirmed the grant of a new trial, rejecting the State’s argument that legal sufficiency precluded the new trial.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Hamilton) | Held |
|---|---|---|---|
| Whether legal sufficiency under Jackson v. Virginia bars a new trial on general grounds | Because evidence was legally sufficient, trial court erred in granting new trial | Trial court may grant new trial despite legal sufficiency by weighing credibility and conflicts in evidence | Court: New trial may stand; legal sufficiency does not bar exercise of general‑grounds discretion |
| Whether the verdict was against the weight of the evidence/principles of justice (general grounds) | Verdict should be upheld because evidence supports convictions | Verdict is decidedly and strongly against the weight of the evidence given testimony of abuse and self‑defense | Court: Trial court did not abuse discretion in granting new trial on general grounds |
| Whether trial counsel provided ineffective assistance (various failures) | State contends trial counsel was adequate; trial court erred finding multiple deficiencies | Hamilton asserted counsel failed to move for pretrial self‑defense immunity, failed to call corroborating witnesses, and failed to object to certain impeachment/prejudicial testimony | Court: Did not decide whether errors require reversal now because many alleged deficiencies are unlikely to recur on retrial; affirmed new trial on general grounds |
| Remedy and retrial consequences | State argues conviction should stand or reversal of new trial order | Hamilton seeks new trial; if retried, may assert self‑defense and other defenses | Court: Affirmed new trial; State may elect to retry; parties/timing should proceed promptly given time served |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (establishes standard for legal sufficiency review)
- White v. State, 293 Ga. 523 (discusses trial judge’s role as thirteenth juror and limits on general‑grounds new trials)
- Anderson v. State, 296 Ga. 524 (addresses sufficiency and appellate review)
- State v. Cash, 298 Ga. 90 (explains appellate deference to trial court’s first grant of new trial)
- State v. Harris, 292 Ga. 92 (discusses standards for granting new trial on general grounds)