White v. State
293 Ga. 523
| Ga. | 2013Background
- Adrian White was tried by a Fulton County jury for malice murder and related offenses in the 2004 fatal shooting of Anthony Jones; jury convicted White on all counts and he received life plus additional consecutive terms.
- Co-defendants Demario Thornton and Marquez Webb were charged; Webb later pled guilty to aggravated assault and testified; Thornton also testified at trial.
- Evidence at trial included testimony that White took a gun, shot Jones in the back while Jones was unarmed, and White, Thornton, and Webb kicked Jones as he lay wounded; multiple witnesses identified White as the shooter.
- The State relied in part on accomplice testimony (Thornton and Webb); the testimony was corroborated by other witnesses and physical indicators (hair style identifications), which the court found sufficient as a matter of law.
- White filed timely motions for new trial raising the general grounds (verdict against the weight of the evidence); the trial court denied the motion, but the appellate court found the trial court applied the wrong legal standard in doing so.
- The Supreme Court of Georgia vacated the denial of the motion for new trial and remanded for the trial court to reexamine the general grounds under the correct standard (trial judge acting as a "thirteenth juror").
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence was legally sufficient to sustain convictions | White did not dispute legal sufficiency at appellate level; argued weight issues for new trial | State argued evidence (including corroborated accomplice testimony and identifications) was sufficient | Court applied Jackson standard and held evidence was legally sufficient for a rational trier of fact to convict |
| Whether the trial court properly applied the standard when denying the general-grounds new trial motion | White argued the trial court failed to exercise discretion to weigh evidence and resolve credibility as required of a "thirteenth juror" | State relied on the trial court’s conclusion that evidence was sufficient under Jackson (legal sufficiency) | Court held the trial court applied the wrong standard (used Jackson legal-sufficiency approach) and remanded for reconsideration under the correct general-grounds standard |
| Proper role of trial judge on general-grounds new trial motion (scope of review) | White urged full exercise of discretion to weigh conflicts, credibility, and evidence weight | State noted limits on successor judge’s deference but maintained trial court discretion | Court reiterated that trial judge must consider credibility and weight; successor judge has narrower but still substantial discretion; new trial review requires sitting as a "thirteenth juror" |
| Admissibility/corroboration of accomplice testimony | White contested reliance on accomplice testimony or its adequacy to sustain convictions | State argued accomplices corroborated each other and other witnesses corroborated accomplice testimony | Court held accomplice testimony was corroborated sufficiently to meet legal-sufficiency standard, but left general-grounds weight determination to trial court on remand |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (legal-sufficiency standard: whether any rational trier of fact could find guilt beyond a reasonable doubt)
- Hayes v. State, 292 Ga. 506 (Ga. 2013) (viewing evidence in light most favorable to verdict for sufficiency review)
- Walker v. State, 292 Ga. 262 (Ga. 2013) (trial judge must act as "thirteenth juror" when ruling on general grounds)
- Choisnet v. State, 292 Ga. 860 (Ga. 2013) (general-grounds review and trial court’s weighing duty)
- Manuel v. State, 289 Ga. 383 (Ga. 2011) (distinguishing legal sufficiency review from trial judge’s discretionary weighing)
- Alvelo v. State, 288 Ga. 437 (Ga. 2011) (general-grounds new trial should be exercised cautiously and only in exceptional cases)
- State v. Harris, 292 Ga. 92 (Ga. 2012) (successor judge’s discretion is narrower when ruling on general-grounds new trial)
- Malcolm v. State, 263 Ga. 369 (Ga. 1993) (vacating felony-murder verdict where appropriate merger applies)
- Herbert v. State, 288 Ga. 843 (Ga. 2011) (one accomplice may corroborate another)
- Handley v. State, 289 Ga. 786 (Ga. 2011) (corroboration of accomplice testimony can satisfy sufficiency)