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Wheeler v. State
293 Ga. 247
Ga.
2013
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Background

  • 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  • Appellant challenged the sufficiency of the evidence for malice murder, arguing his confession was retracted and only Jenkins’ testimony and his own trial testimony remained corroborative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Sufficiency of malice murder evidence Wheeler contends the confession was retracted and only Jenkins’ testimony and his trial testimony prove guilt State argues Jenkins’ credible testimony and Wheeler’s admissions suffice to prove malice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)
Read the full case

Case Details

Case Name: Wheeler v. State
Court Name: Supreme Court of Georgia
Date Published: Jun 17, 2013
Citation: 293 Ga. 247
Docket Number: S13A0776
Court Abbreviation: Ga.