Wilson v. State
295 Ga. 84
| Ga. | 2014Background
- Roland Wilson was convicted of felony murder for the beating death of William Okafor during a July 26, 2009 incident at Okafor's home in Newton County.
- Okafor was attacked with a brick by Wilson and others; he suffered a severe head injury and died five days later.
- Mrs. Sharp, Okafor’s mother, identified Wilson as the brick attacker; Reid testified that Wilson beat Okafor after the barbeque.
- Mr. Sharp, Okafor’s stepfather, had died before trial; Reid testified that Mr. Sharp identified Wilson as the attacker and that Wilson used a brick.
- Walter McFalls testified that Wilson admitted hitting Okafor with a brick in a jail card-game conversation, allegedly bragging about evading accountability.
- The defense argued that Bryant, not Wilson, hit the victim, and urged the jury to credit that alternate theory; the State argued the evidence supported guilt beyond a reasonable doubt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Wilson’s guilt rests on unreliable witnesses and an alternate killer theory. | Credible witnesses and direct evidence support guilt beyond reasonable doubt. | Evidence sufficient for conviction |
| Admissibility of out-of-court statements under necessity | Mr. Sharp’s statements to Reid were improperly admitted as hearsay. | Statements were admissible under the necessity/excited utterance framework. | Admission not reversible error |
| Prosecutor's closing remarks and mistrial | Prosecutor’s improper comments warranted a mistrial. | Court gave curative instructions; mistrial unnecessary. | No mistrial required; curative instruction sufficient |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court, 1979) (sufficiency review standard for criminal convictions)
- Vega v. State, 285 Ga. 32 (Ga. Supreme Court, 2009) (credibility determinations for witness testimony)
- Brown v. State, 291 Ga. 892 (Ga. Supreme Court, 2012) (circumstantial-evidence sufficiency guidance)
- Mallory v. State, 261 Ga. 625 (Ga. Supreme Court, 1991) (necessity/exceptions to hearsay rulings)
- Willis v. State, 274 Ga. 699 (Ga. Supreme Court, 2002) (excited utterance and res gestae considerations)
- McKibbins v. State, 293 Ga. 843 (Ga. Supreme Court, 2013) (trial court discretion on mistrial decisions)