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Stuckey v. State
301 Ga. 767
| Ga. | 2017
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Background

  • 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)
Read the full case

Case Details

Case Name: Stuckey v. State
Court Name: Supreme Court of Georgia
Date Published: Aug 14, 2017
Citation: 301 Ga. 767
Docket Number: S17A1175
Court Abbreviation: Ga.