Woods v. State
291 Ga. 804
| Ga. | 2012Background
- Woods appeals convictions for malice murder, aggravated assault, firearm possession during a felony, and concealing a death, arising from Travis Sauls's death; the court reverses.
- Sauls lived at Woods's cousin Gross's home; Woods lived nearby and invited Sauls to paint and wash his truck on Sept. 28–29, 2009.
- Neighbors heard 3–4 gunshots from Woods's home around 11:00 a.m. on Sept. 29; Sauls was later found burned and dismembered on Woods's hunting property in Florida.
- Woods told his father and others he killed Sauls in self-defense, disposed of the body in Florida, and later returned to Georgia; investigators found partially burned clothing and a hidden pistol tying to the murder.
- Woods cooperated with law enforcement after a meeting on Oct. 3–7, with counsel present; suppression motions and ineffective assistance claims were litigated.
- The trial court denied ineffective assistance; Woods sought new trial on several grounds, including jury instructions about delusional compulsion and justification.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the absence of a justification instruction for delusional compulsion taints the verdicts. | Woods contends delusional compulsion defense requires justification instruction. | State argues no written request, thus no error; jury could apply delusional compulsion without justification guidance. | New trial required due to lack of proper justification instruction. |
Key Cases Cited
- Jackson v. Virginia, 443 U. S. 307 (U.S. 1979) (standard for sufficiency of evidence to support verdict)
- Strickland v. Washington, 466 U. S. 668 (U.S. 1984) (ineffective assistance standard: deficient performance and prejudice)
- Smith v. Francis, 253 Ga. 782 (Ga. 1985) (precedes Strickland in Georgia; standard for ineffective assistance)
- Camphor v. State, 272 Ga. 408 (Ga. 2000) (written instruction requirement for certain objections)
- Shepherd v. State, 280 Ga. 245 (Ga. 2006) (court not required to charge collateral matters without written request)
- Hayes v. State, 279 Ga. 642 (Ga. 2005) (trial court not required to charge without written request for collateral matter)
- Alvelo v. State, 290 Ga. 609 (Ga. 2012) (delusional compulsion defense requires a justified delusion)
- Lawrence v. State, 265 Ga. 310 (Ga. 1995) (delusional compulsion defense limited to absurd delusions that compel lawful conduct)