Walden v. State, 289 Ga. 845

Walden was convicted after a jury trial of malice murder, felony murder (vacated by operation of law), possession of a firearm during a crime, concealing the death of another, and two counts of cruelty to children in the second degree.
The victim, Johnny Clint Walden, allegedly taught Walden how to shoot a gun; Walden lied about large debts and had threatened marital dissolution.
The victim was killed by a single gunshot to the head at his residence; pathologist termed the death homicide with no confirmed contact wound.
Walden remained in the home with the two children for about three days, concealing the body and giving inconsistent accounts to relatives.
Walden claimed the death was suicide in some statements, but she also told others that the shooting was intentional after a financial dispute.
The trial court entered judgments on the guilty verdicts other than felony murder, with life imprisonment for malice murder and concurrent ten-year terms for cruelty to children, while a companion appellate challenge raised sufficiency and venue issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for malice murder and cruelty to children	Walden argues evidence does not support malice murder or second-degree cruelty.	State contends circumstantial and testimonial evidence adequately proves guilt beyond reasonable doubt.	Evidence sufficient to sustain all convictions.
Change of venue from juvenile or small community prejudicial error	Walden argues venue should have been changed due to community size and pretrial opinions.	State contends no inherent prejudice or actual prejudice requiring venue change.	No abuse of discretion; venue denial affirmed.

Evans v. State, 271 Ga. 614 (1999) (premise that a suicide theory is a matter for jury)
Garey v. State, 273 Ga. 133 (2000) (circumstantial evidence allows jurors to reject suicide hypothesis)
Wright v. State, 274 Ga. 730 (2002) (circumstantial evidence supports homicide verdict)
Hall v. State, 287 Ga. 755 (2010) (reaffirmed sufficiency in circumstantial cases)
Brewton v. State, 266 Ga. 160 (1996) (unsanitary conditions may support cruelty to children; malice required)
Staib v. State, 309 Ga.App. 785 (2011) (odor and unsanitary conditions feeding cruelty evidence)
Gear v. State, 288 Ga. 500 (2011) (voir dire and change-of-venue standards; recording issues)
Graham v. State, 246 Ga. 341 (1980) (recording/voir dire evidentiary requirements for preservation)
Bryant v. State, 270 Ga. 266 (1998) (voir dire recordation standards)