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