Stuckey v. State
301 Ga. 767
| Ga. | 2017Background
- In March 2009, 15-year-old Dominique Javonte Stuckey lived with his grandmother; she disapproved of his sexual orientation and online contacts with older men.
- On March 29, 2009, the grandmother was found beaten, stabbed, and burned to death in her bedroom; forensic evidence showed an ignitable liquid poured and ignited to conceal the crime, and the victim had smoke/soot and high carbon monoxide levels.
- Appellant’s SUV, which he had taken that morning, smelled of gasoline; vehicle carpet and items found in nearby woods tested positive for gasoline; a deleted computer search for “how to kill someone” was recovered.
- Stuckey initially denied involvement, then admitted setting the fire but blamed an older boyfriend for the initial attack; that alleged boyfriend denied involvement.
- A jury convicted Stuckey of malice murder and first-degree arson; he was sentenced to life plus 20 years. He moved for a new trial claiming ineffective assistance of counsel; the trial court denied relief and the Georgia Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument (Stuckey) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Trial counsel waived foundation for MySpace printout | Counsel was ineffective for not challenging authenticity/foundation of a 400‑page MySpace printout | Counsel had a stipulation with prosecutor and waived foundation as reasonable trial strategy; objection unlikely to exclude it | No deficient performance or prejudice; waiver was reasonable and objection unlikely to have changed outcome |
| Failure to object to MySpace evidence as irrelevant/prejudicial | MySpace photos/comments were irrelevant and unduly prejudicial | Photos supported defense theory about Appellant’s relationships and vulnerability; counsel used them strategically | Strategy was reasonable; even if some objection would succeed, no reasonable probability of different result |
| Failure to object to gruesome crime‑scene/autopsy photos | Counsel should have objected as duplicative and prejudicial | Photos showed distinct views and were admissible under then‑applicable law; some post‑incision photos were relevant to internal findings | No deficient performance; objections would have been meritless and not prejudicial |
| Failure to object to life photographs and family identification | Photos and family testimony identifying victim were prejudicial | Even if some should be excluded, overwhelming evidence of guilt meant no prejudice | No prejudice shown; claim fails |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (review of sufficiency of evidence standard)
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard)
- Vega v. State, 285 Ga. 32 (jury resolves credibility and conflicts)
- Lupoe v. State, 300 Ga. 233 (Strickland application in Georgia)
- Wallace v. State, 296 Ga. 388 (foundational objections and electronic evidence)
- Hayes v. State, 298 Ga. 98 (handling foundational matters)
- McLean v. State, 297 Ga. 81 (deference to strategic decisions of counsel)
- Sullivan v. State, 301 Ga. 37 (overwhelming evidence and prejudice analysis)
- Wilcher v. State, 291 Ga. 613 (admissibility of pre‑autopsy scene photographs)
- Banks v. State, 281 Ga. 678 (post‑incision autopsy photos admissible for internal injuries)
- Moss v. State, 298 Ga. 613 (failure to make meritless objection not ineffective)
- Haynes v. State, 287 Ga. 202 (preferring non‑family identifiers for victim photos)
- Flowers v. State, 275 Ga. 592 (guidance on victim‑in‑life photographs)
- Ragan v. State, 299 Ga. 828 (post‑Evidence Code considerations on photos)
