State v. Jackson
294 Ga. 9
| Ga. | 2013Background
- State appealed trial court's grant of a new trial on legal-sufficiency grounds under Jackson v. Virginia.
- Trial court reviewed legal sufficiency (not under OCGA § 5-5-21) and invalidated the verdict as insufficient.
- Appellee Marcus Jackson and co-defendant Eskie Christmas were charged with malice murder, felony murder, aggravated assault, and gun possession for the August 8, 2007 killing.
- Evidence showed Jackson directed, accompanied, and aided in the confrontation, including bringing the gun and pistol-whipping the victim, with a fatal shot fired by Christmas.
- Medical and firearms testimony indicated a gunshot to the head at close range, with the gun in working order and a heavy trigger pull.
- Appellate court held there was sufficient evidence for Jackson to be found guilty as a party to the crimes; reversed the trial court's new-trial grant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence was legally sufficient to convict Jackson | State argues sufficient evidence under Jackson v. Virginia | Jackson contends insufficient evidence to convict as a party | Evidence sufficient to support conviction as a party |
| Whether Jackson could be convicted as a party to the crimes | Presence and conduct show intent and participation | Trial court erred in concluding no aiding or abetting | Yes; Jackson was a party to the crimes |
| Whether the trial court properly granted a new trial based on insufficiency | New-trial order was correct due to insufficiency | Insufficiency did not exist; no reversal warranted | No; reversal of trial court's grant of new trial |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. (1979)) (standard: rational juror could convict beyond reasonable doubt)
- Manuel v. State, 289 Ga. 383 (Ga. 2011) (plain error-free standard for sufficiency review)
- Colzie v. State, 289 Ga. 120 (Ga. 2011) (applies Jackson v. Virginia standard on appeal)
- Powell v. State, 291 Ga. 743 (Ga. 2012) (party-to-crime liability shown by presence, conduct, intent)
- Williams v. State, 291 Ga. 501 (Ga. 2012) (party liability principles corroborated)
- Teasley v. State, 288 Ga. 468 (Ga. 2011) (evidence of intent to participate)
- Allen v. State, 288 Ga. 263 (Ga. 2010) (participation elements in crime)
- Cook v. State, 314 Ga. App. 289 (Ga. App. 2012) (reaffirmation of party-liability standards)
- Burgess v. State, 292 Ga. 821 (Ga. 2013) (evidence of attempted influence and participation)
- Ricketts v. Williams, 242 Ga. 303 (Ga. 1978) (new trial standards; role of sufficiency review)