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Stokes v. State
289 Ga. 702
Ga.
2011
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Background

  • Stokes was convicted of murder, felony murder, cruelty to children, and aggravated battery in Georgia.
  • The four-month-old victim Jeremiah Stokes died from injuries the medical examiner attributed to manual forcible suffocation with the hands.
  • Stokes admitted actions against the baby during interviews and trial, including squeezing, face and neck pressure, and flipping the baby.
  • Autopsy revealed multiple injuries (broken ribs, torn gum/lip, facial/neck bruising, broken arm, swollen brain) consistent with violent handling.
  • Evidence included a prior incident where Stokes squeezed and threw the baby toward Riley, demonstrating a pattern of conduct toward the child.
  • Stokes challenged evidence issues, Batson claims, and the admissibility of photographs and prior injuries at trial.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of the evidence Stokes argues evidence insufficient to convict. State contends the autopsy and statements prove intent and causation. Evidence supports guilt beyond a reasonable doubt.
Ineffective assistance – Batson challenge Stokes claims counsel should have raised Batson; prejudice shown. State had race-neutral explanations; lack of proof of prejudice. No ineffective assistance; failure to establish merit.
Admission of prior difficulties evidence Prior incident similarity required; probative value outweighed by prejudice. Prior acts show bent of mind and relationship with victim; admissible. Evidence properly admitted; relevant to motive/intent.
Admission of photographs and testimony about prior injuries Photos of prior injuries unduly prejudicial. Photos assist mechanism of death and relate to prior conduct. No abuse of discretion; probative value outweighs prejudice.

Key Cases Cited

  • Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency standard for criminal evidence)
  • Batson v. Kentucky, 476 U.S. 79 (1986) (peremptory challenge race neutrality framework)
  • Pierce v. State, 286 Ga. 194 (2009) (ineffective assistance standard for failure to raise suppression motions)
  • Stanley v. State, 283 Ga. 36 (2008) (need strong showing to suppress evidence in ineffective assistance context)
  • Dixon v. State, 275 Ga. 232 (2002) (admissibility of prior difficulties in related crimes; nexus requirement)
  • Trammel v. State, 265 Ga. 156 (1995) (State not required to produce prosecutors' notes at motion in suppression context)
  • Malcolm v. State, 263 Ga. 369 (1993) (murder conviction framework and related procedures)
Read the full case

Case Details

Case Name: Stokes v. State
Court Name: Supreme Court of Georgia
Date Published: Sep 12, 2011
Citation: 289 Ga. 702
Docket Number: S11A1011
Court Abbreviation: Ga.