Willis v. State
304 Ga. 781
Ga.2018Background
- On August 13, 2014, Robert Lee Murry, Jr. was shot and killed at his family auto shop in Griffin, Georgia; two spent bullets and the firearm were recovered near the scene.
- Christopher Antwan Willis was arrested shortly after; eyewitnesses testified Willis shot at Murry’s father and fled; Murry’s brother saw Willis holding a gun as Murry bled.
- Willis’s defense: an accidental discharge during a struggle after Murry allegedly produced a gun; Willis said he fled in fear and discarded clothing to avoid recognition.
- A jury convicted Willis of malice murder, felony murder, aggravated assaults, and firearm offenses; he received life for malice murder plus consecutive and concurrent terms on other counts.
- Willis appealed, raising (1) sufficiency of the evidence, (2) admission of a crime-scene investigator’s testimony as improper opinion, and (3) failure to instruct the jury about the mandatory life sentence for murder.
Issues
| Issue | Plaintiff's Argument (Willis) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Sufficiency of the evidence for murder convictions | Evidence was largely circumstantial and consistent with accidental shooting during self-defense; alternate reasonable hypothesis of innocence exists | Eyewitnesss and circumstantial facts (shooting at father, immediate flight, attempts to evade police, Murry’s limited use of one hand) support guilt beyond a reasonable doubt | Affirmed: evidence sufficient when viewed in light most favorable to verdict; jurors could reject Willis’s account |
| Admission of crime-scene investigator testimony (opinion on bullet that killed Murry, wound orientation, blood pattern, posture) | Testimony amounted to improper non-expert/ultimate-issue opinion; prejudiced defense; counsel’s failure to object rendered ineffective assistance | Even if testimony erred, Willis did not show it affected outcome; defense theory (accident) not inconsistent with investigator’s statements; no prejudice for plain-error review or ineffective-assistance claim | No plain error; no reversible error; ineffective-assistance claim fails for lack of prejudice |
| Trial court’s failure to instruct jury that murder carries mandatory life sentence | Jury should have been told a guilty verdict would carry mandatory life; omission was error | No controlling authority requires informing jury of specific mandatory sentence; prior precedent rejects such instruction requirement | No plain error; trial court not required to inform jury of mandatory sentence prior to verdict |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence)
- Daniels v. State, 298 Ga. 120 (2015) (circumstantial evidence must exclude reasonable hypotheses of innocence)
- Graham v. State, 301 Ga. 675 (2017) (jury decides witness credibility; adverse resolution does not make evidence insufficient)
- McClain v. State, 303 Ga. 6 (2018) (flight after shooting may indicate consciousness of guilt)
- Benton v. State, 301 Ga. 100 (2017) (plain-error review framework)
- Johnson v. State, 276 Ga. 57 (2002) (trial court not required to inform jury of mandatory sentence)
- Strickland v. Washington, 466 U.S. 668 (1984) (ineffective-assistance-of-counsel standard)
- Doleman v. State, 304 Ga. 740 (2018) (no plain error for failure to instruct jury about mandatory murder sentence)