Wilson v. State
293 Ga. 508
| Ga. | 2013Background
- July 26, 2010: Ronnie Lee Wilson and Reginald Williams became involved in a fight in the back seat of a car after a drug transaction; a single gunshot fatally wounded Williams (hard contact wound). Wilson drove off in the victim’s car.
- Witnesses (Gerald Johnson and Darrell Simmons) testified only Wilson and Williams were in the car when the shot occurred; Johnson testified Wilson admitted shooting Williams.
- Wilson gave varying recorded statements to police: initially claiming self-defense, later blaming Simmons, then alleging a fourth person fired.
- Wilson had a 2005 guilty plea to two counts of aggravated assault with intent to rob arising from a different shooting; the State sought to admit that prior conduct as a similar transaction.
- Procedural posture: Convicted at jury trial of felony murder (predicated on aggravated assault and felon-in-possession), related felonies, and sentenced to life without parole; appeal from denial of motion for new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Wilson: evidence insufficient because no witness saw him fire the gun | State: circumstantial and forensic evidence plus witness testimony placed only Wilson and Williams in car when shot; forensic wound consistent with contact firing during struggle | Affirmed – evidence sufficient under Jackson v. Virginia standard |
| Admissibility of custodial recorded statement (voluntariness) | Wilson: statement induced by hope of benefit (detective’s comment after "help me out") rendering it involuntary under former OCGA § 24-3-50 | State: no promise of leniency or reduced charges; detective’s comment noncommittal and not a promise of benefit | Affirmed – no inducement; statement admissible; review de novo when record undisputed |
| Admission of prior guilty plea as similar transaction evidence | Wilson: prior plea was prejudicial and not sufficiently similar or proper purpose | State: offered prior plea to show course of conduct; similarities in targeting, violence, location, flight, and denials; trial court gave limiting instruction | Affirmed – admission proper for limited purpose; trial court did not abuse discretion |
| Standard for admitting similar transaction evidence | Wilson: (implicit) prior-act rule should exclude the evidence | State: relied on existing Georgia precedent allowing such evidence for proper purposes | Affirmed – applied pre-2013 Georgia standards for independent acts and abuse-of-discretion review |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence review)
- Brown v. State, 290 Ga. 865 (de novo review of voluntariness when recorded interview is in the record)
- Canty v. State, 286 Ga. 608 (confession involuntary when induced by possibility of shorter imprisonment)
- State v. Ray, 272 Ga. 450 (confession involuntary when implied promise could avoid death penalty)
- Abdullah v. State, 284 Ga. 399 (three-part test for admissibility of independent-act evidence)
- Moore v. State, 288 Ga. 187 (abuse-of-discretion review for similar transaction evidence)
- Harvey v. State, 292 Ga. 792 (permissible purposes for similar transaction evidence)
- Barnes v. State, 287 Ga. 423 (discussion of admitting prior convictions/pleas for course-of-conduct purposes)