Woodall v. State
294 Ga. 624
| Ga. | 2014Background
- Appellant Lecester “Buddy” Woodall, Jr. was tried separately for two counts of malice murder and one count of armed robbery for the September 4, 2000 shootings of John Lynn and Robert Van Allen; jury convicted him of two counts of felony murder (based on aggravated assault) and one count of armed robbery and imposed consecutive life sentences.
- Prosecution evidence: lure phone call traced to a pay phone captured on surveillance showing appellant nearby; eyewitnesses saw a light-blue Pontiac and two men near the wrecker; appellant’s tire tracks matched tracks at the scene; a pearl‑handled .25 Lorcin (matching wounds) had been stolen earlier from appellant’s parents’ home; victims’ wallets and other physical evidence linked to the defendants; appellant later confessed after an extended interrogation.
- Appellant asserted numerous trial errors on appeal, including improper juror seating, Batson challenge to a peremptory strike of an African‑American juror, voluntariness of his recorded confession, exclusion of an expert on false confessions, admission of prior‑statement/hearsay evidence, admission of burglary evidence, limits on defense proof of alternative suspects, judge recusal, merger of convictions, and cumulative error.
- The trial court admitted the video confession after finding it voluntary; excluded the defense expert on false confessions for lack of scientific reliability; admitted prior inconsistent statements for impeachment (with limiting instructions) and burglary evidence to show access to a weapon; denied recusal and other defense motions.
- On appeal the Georgia Supreme Court reviewed these claims and affirmed the convictions, finding the evidence sufficient and no reversible error in the trial court’s evidentiary and procedural rulings.
Issues
| Issue | Woodall's Argument | State's Argument | Held |
|---|---|---|---|
| Juror illegally seated (wrong identity on summons) | Must get new trial because juror Cynthia L. Battle did not match master list (Cynthia R. Battle) | Woodall had access to master list and failed to exercise ordinary diligence; no timely objection | Waived — no timely objection; no new trial |
| Batson challenge to strike of African‑American juror Linda Dallas | Strike was racially motivated; comparable white jurors rated similarly on death‑penalty scale | Strike was race‑neutral (Dallas said “all life is precious,” rated herself low; others either clarified rating or differed) | Trial court not clearly erroneous; Batson denial affirmed |
| Voluntariness of recorded confession; induced by promise he could go home | Statement involuntary due to intoxication, fatigue, length, and implication he could go home (hope of benefit) | Interrogation circumstances and Miranda waivers showed voluntariness; no promises of leniency | Statement voluntary; admissible |
| Exclusion of expert on false confessions (Dr. Leo) | Testimony would show interrogation techniques and risk of false confession | Expert field lacks sufficient scientific reliability; prior GA precedent excludes such testimony | Exclusion proper; no abuse of discretion |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (sufficiency of evidence standard)
- Batson v. Kentucky, 476 U.S. 79 (three‑step Batson framework for race‑based peremptory challenges)
- Edenfield v. State, 293 Ga. 370 (voluntariness standard; de novo review of law, defer to trial court facts)
- McIlwain v. State, 264 Ga. 382 (lengthy interrogation and voluntariness)
- Dennis v. State, 293 Ga. 688 (slightest hope of benefit test for voluntariness)
- Wright v. State, 285 Ga. 428 (expert testimony on false confessions inadmissible due to reliability concerns)
- Lyons v. State, 282 Ga. 588 (same; limitations on false‑confession expert testimony)
- Riley v. State, 278 Ga. 677 (same)
- Holiday v. State, 272 Ga. 779 (prior inconsistent statements admissible for impeachment and, when witnesses available, as substantive evidence)
- Crozier v. State, 263 Ga. 866 (relevance standard; evidence that sheds light on material issues admissible)
- Klinect v. State, 269 Ga. 570 (standards for third‑party guilt evidence—must directly connect other person to corpus delicti)
- Briscoe v. State, 263 Ga. 310 (merger rules when underlying felony for felony‑murder unclear)
- Drinkard v. Walker, 281 Ga. 211 (armed robbery distinct from separate aggravated assault supporting felony murder)
- Rice v. State, 292 Ga. 191 (Georgia does not apply cumulative‑error rule)
- In re Adams, 292 Ga. 617 (failure to timely seek recusal waives claim)