Wheeler v. State
290 Ga. 817
Ga.2012Background
- Wheeler was convicted by a jury of malice murder, felony murder, and aggravated assault for the strangling, beating, and stabbing death of his elderly, wheelchair-bound ex-girlfriend Pearl Johnson.
- Johnson allowed Wheeler to enter her home on January 6, 2007; her body was found the next day with evidence of beating, stabbing, and strangulation; blood evidence linked Wheeler to the crime.
- Wheeler's history of domestic violence against Johnson and other women was proven through testimony from his ex-wife and three ex-girlfriends, plus testimony from Johnson's children; a letter by Johnson suggested Wheeler should be investigated if she were killed.
- The State presented blood evidence and a pattern of Wheeler choking, beating, and threatening women with a knife to support a criminal trajectory toward Johnson.
- The trial court admitted similar-transaction evidence about Wheeler's prior assaults on his ex-wife and ex-girlfriends, with the court balancing probative value against potential prejudice.
- Wheeler received a life sentence for malice murder; the felony-murder conviction was vacated by operation of law and the aggravated assault count merged for sentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Wheeler | Wheeler | Evidence sufficient to support malice murder verdict |
| Admissibility of similar transactions given time lapse | Wheeler | Wheeler | Prior acts admissible; probative value outweighed prejudice |
| Denial of cause challenges to jurors | Wheeler | Wheeler | No abuse of discretion in not excusing jurors |
| Admission of Johnson-letter evidence | Wheeler | Wheeler | Chain of custody not required for non-fungible physical evidence |
| Ineffective assistance and newly discovered evidence | Wheeler | Wheeler | No basis for new trial; strategy reasonable; no prejudice shown |
Key Cases Cited
- Rogers v. State, 290 Ga. 401 (2012) (time lapse affects weight not admissibility of similar transactions)
- Neal v. State, 290 Ga. 563 (2012) (similar transactions need not be timely to be admissible; balance probative value and prejudice)
- Pareja v. State, 286 Ga. 117 (2009) (no bright-line rule that acts older than 30 years are inadmissible)
- Mize v. State, 269 Ga. 646 (1998) (non-fungible physical evidence identified by observation; no chain of custody needed)
- Reed v. State, 285 Ga. 64 (2009) (reasonableness of trial strategy reviewed on appeal)
- Braithwaite v. State, 275 Ga. 884 (2002) (no ineffective assistance where trial strategy strategic)
- McClain v. State, 267 Ga. 378 (1996) (judicial deference to trial court credibility and decision-making)
- Robinson v. State, 277 Ga. 75 (2003) (appellate review of factual findings and credibility)