Wheeler v. State
293 Ga. 247
Ga.2013Background
- Appellant Wheeler was convicted of malice murder, armed robbery, and related offenses for the shooting death of Steven Green.
- Jenkins arranged a meeting with Green at a rental home; Wheeler, hidden inside the home, robbed Green and fatally shot him.
- Wheeler admitted to luring Green and shooting him in police interview, then told others to keep quiet.
- At trial Wheeler testified he confessed only to protect Jenkins but participated in planning and execution of the robbery.
- Jenkins testified for the State under a plea agreement, supporting Wheeler's direct involvement in the crimes.
- Appellant challenged the sufficiency of the evidence for malice murder, arguing his confession was retracted and only Jenkins’ testimony and his own trial testimony remained corroborative
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of malice murder evidence | Wheeler contends the confession was retracted and only Jenkins’ testimony and his trial testimony prove guilt | State argues Jenkins’ credible testimony and Wheeler’s admissions suffice to prove malice murder | Evidence sufficient to support guilt beyond reasonable doubt |
Key Cases Cited
- Merritt v. State, 292 Ga. 327, 330 (737 SE2d 673) (2013) (Ga. 2013) (confession corroborated by independent evidence)
- Nicely v. State, 291 Ga. 788, 790 (1) (733 SE2d 715) (2012) (Ga. 2012) (jury credibility resolves conflicts; adverse result not insufficiency)
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (standard for reviewing sufficiency of evidence)
