Stephens v. State
303 Ga. 530
Ga.2018Background
- In June 2007 one-year-old Jewell Williams died after ingesting cocaine; Stephens and co-defendant Anthony Williams lived in the same home.
- Emergency responders found a crystalline substance near the sofa and trace cocaine in a seized vacuum cleaner bag from the home.
- Multiple witnesses testified that cocaine was sold from Stephens’s home, often loose (unpackaged), with children present during transactions.
- Stephens and Williams initially told police that a third person (Frieda Wofford) brought cocaine into the house that night; Wofford denied being present that evening but admitted prior purchases from the home.
- Stephens was convicted at trial on eight counts (four felony-murder counts and four predicate felonies) and sentenced to four concurrent life sentences; the trial court later merged or vacated all convictions except one felony-murder count (Count 1: felony murder predicated on possession with intent to distribute).
- On appeal Stephens challenged multiple convictions (most moot due to merger), and principally argued that the State failed to prove a sufficient nexus between the underlying drug distribution offense and Jewell’s death for Count 1.
Issues
| Issue | Stephens' Argument | State's Argument | Held |
|---|---|---|---|
| Mootness of challenges to counts other than Count 1 | Challenges to merged or vacated counts remain reviewable | Merger/vacatur left only Count 1 as operative, rendering other challenges moot | Court: Arguments about merged/vacated counts are moot; only Count 1 remains live |
| Sufficiency of evidence / nexus between drug offense and death (Count 1) | State failed to prove the drug offense was dangerous per se or created a foreseeable risk of death; no proven nexus between possession-with-intent-to-distribute and Jewell’s ingestion/death | Evidence showed cocaine was stored in places used to sell (sofa/purse), cocaine was loose, transactions occurred with children present, and the victim ingested a deadly dose found where the defendants stored drugs | Court: Evidence sufficient; victim ingested the lethal dose after finding cocaine where Stephens and Williams stored it to sell, supporting felony-murder conviction on Count 1 |
Key Cases Cited
- Williams v. State, 298 Ga. 208 (affirming nexus where victim ingested cocaine found where defendants stored drugs to sell)
- Dixon v. State, 302 Ga. 691 (discussing effect of vacatur/merger on sentencing and verdicts)