Thompson v. State, 295 Ga. 96

Appellant Rodney Thompson was convicted of felony murder of his mother, Marjorie Lynch, after trial in Georgia.
Evidence showed Thompson lived with Lynch; a month earlier Lynch demanded he help with household bills or move out.
On June 5, 2008, Lynch called 911 claiming her son stabbed her; deputies found Thompson on the porch and he eventually admitted he had stabbed her.
Lynch died from a crossbow bolt wound; the bolt had a field tip, suggesting practice use rather than hunting.
Investigators found a crossbow and bolt in Thompson’s room; a Bass Pro Shop associate testified Thompson purchased the crossbow within two months of the shooting and could demonstrate its use.
During custodial interrogation, Thompson made several statements; he also had a 1994 New Jersey conviction for threatening to kill his mother.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for felony murder	Thompson argues evidence favors accident.	Thompson contends the State failed to prove intent and thus no felony murder.	Evidence supported felony murder beyond reasonable doubt.
Admissibility of expert IQ testimony	IQ 67 evidence could support lack of intent/accident defense.	IQ evidence relevant to mental disability affecting understanding of crossbow use.	Trial court correctly excluded such evidence under longstanding precedent.
Admissibility of prior difficulties with victim	Records of prior threats show motive and relationship context.	Evidence should be excluded for timeliness and remoteness.	Court did not abuse discretion; prior threats properly admitted.
Miranda violation and admission of statements	Interrogation during interview tainted later statements.	Statements obtained during custodial conference room were tainted.	Guthas’s testimony about statements properly admitted; no coercive interrogation shown.
Confrontation Clause preservation	Right to cross-examine the records was at issue.	Waived Confrontation Clause review.	Confrontation Clause claim waived; no review required.

Jackson v. Virginia, 443 U.S. 307 (1981) (sufficiency standard for criminal evidence)
Wall v. State, 269 Ga. 506 (1998) (prior acts evidence relates to motive/intent; remoteness affects weight, not admissibility)
Reece v. State, 212 Ga. 609 (1956) (weak-mindedness not defense to crime unless insanity)
State v. Brown, 287 Ga. 473 (2010) (functional equivalence of interrogation and custody guidance)
Bryant v. State, 271 Ga. 99 (1999) (exclusion of mental-condition evidence where not relevant to defense)
Abernathy v. State, 289 Ga. 603 (2011) (mental abnormality not defense absent insanity)