Thompson v. State
294 Ga. 693
Ga.2014Background
- Thompson was convicted of felony murder and related charges for the April 4, 2010 death of Reynaldo Jackson.
- Evidence showed Thompson shot Jackson in a DeKalb County apartment complex area while Williams was nearby; Thompson urged Williams to help move the body and clean the vehicle.
- Thompson hid the gun and bloodied shirt; Williams discarded Thompson’s shirt and aided in locating evidence.
- Victim’s body discovered in the truck; investigators recovered the weapon, shirt, shell casings, and bullets; DNA, fingerprint, and ballistics evidence connected Thompson to the crime.
- Thompson testified he did not commit the crime; Williams allegedly confessed to the shooting in Thompson’s account.
- Trial from January 31 to February 8, 2011 resulted in guilty verdicts on all counts except malice murder; life sentence imposed for felony murder with additional firearm sentence; appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to sustain the conviction | Thompson argues insufficient evidence under Jackson v. Virginia | State contends sufficient proof from ballistic, DNA, fingerprint, and eyewitness testimony | Evidence sufficient to support guilty verdicts |
| Ineffective assistance—failure to object to prosecutor’s opinion statement | Counsel was ineffective for not objecting to the prosecutor's expression of guilt | Prosecutor’s question did not change outcome; substantial evidence supports guilt | No merit; trial court’s ruling affirmed |
| Prosecutor’s conduct/claims of misconduct | Appellant argues prosecutorial misconduct in light of earlier question | Waived review by failure to contemporaneously object | Waived; no reversible error |
| Admission of prior difficulties testimony under necessity exception | Testimony about prior disputes violated Sixth Amendment confrontation; insufficient trustworthiness | Trial court properly found indicia of trustworthiness; close relationship between victim and witnesses | No abuse of discretion; testimony admissible under necessity exception |
| Juror for-cause challenge and potential bias | Juror 9 potentially biased due to felon status; should have been excused for cause | Trial court did not abuse discretion; juror stated willingness to be fair | No reversible error; juror not excused for cause; proper discretion exercised |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard for criminal convictions)
- Pruitt v. State, 282 Ga. 30 (Ga. 2007) (ineffective assistance standard; two-prong test)
- Wright v. State, 291 Ga. 869 (Ga. 2012) (two-prong test applicability if one prong fails)
- Sanders v. State, 289 Ga. 655 (Ga. 2011) (contemporaneous objection requirement to preserve error)
- Johnson v. State, 294 Ga. 86 (Ga. 2013) (trustworthiness and necessity analysis for hearsay exceptions)
- Belmar v. State, 279 Ga. 795 (Ga. 2005) (trustworthiness assessment for necessity exception to hearsay)
- Davis v. State, 294 Ga. 486 (Ga. 2014) (trustworthiness in testimony reconnecting with close relationship)