Wright v. State
310 Ga. App. 80
Ga. Ct. App.2011Background
- In 1994, a Fulton County grand jury indicted Chambers and Wright for 12 offenses against four women: rape, aggravated sodomy, kidnapping, and armed robbery (Counts 1–4); rape, armed robbery, and kidnapping (Counts 5–7); armed robbery (Count 8); and rape, aggravated sodomy, kidnapping, and aggravated assault (Counts 9–12).
- Chambers pleaded guilty and testified against Wright; DNA from B.J.C. and K.W. supported Chambers, and one semen sample from K.W. matched Wright on two of five markers with a low population frequency.
- In 1995 Wright was convicted on all counts and sentenced to three life terms plus four 20-year terms.
- In 2006 Wright obtained post-conviction DNA testing under OCGA § 5-5-41(c) showing he could not have donated the semen from K.W.; the test excluded him as the donor.
- In 2009 Wright, pro se, sought a new trial based on newly discovered evidence; the trial court granted new trial on Counts 9–12 (K.W.) but denied Counts 1–8.
- The Georgia Court of Appeals granted discretionary review to address whether the trial court abused its discretion denying a new trial on Counts 1–8.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the new DNA evidence was so material as to likely change the verdict on Counts 1–8. | Wright argues exoneration on K.W. would exonerate him on other counts. | State argues there is strong other evidence of guilt (fingerprints, identity, patterns) for Counts 1–8. | No abuse of discretion; new DNA evidence not likely to yield a different verdict on Counts 1–8. |
| Whether the fingerprint evidence, independent of DNA, sustained Wright's guilt on the other counts. | Wright points to irregularities and chain-of-custody issues to cast doubt on fingerprint evidence. | Fingerprints were admissible and sufficiently connected Wright to K.M.’s vehicle with no showing of material tampering. | Fingerprints remain probative; not sufficient to overturn the verdict on Counts 1–8. |
| Whether the common features of the four crimes establish a single two-perpetrator theory excluding Wright for all counts. | The crimes’ similarities imply the same two perpetrators; exoneration for K.W. undermines all Counts. | Similarities exist but do not prove Wright committed all Counts; K.W. DNA does not negate other evidence. | Notwithstanding similarities, DNA exclusion for K.W. does not require reversal on Counts 1–8. |
Key Cases Cited
- Crowe v. State, 265 Ga. 582 (1995) (extraordinary motion for new trial standards; high materiality requirement for new-evidence relief)
- Manning v. State, 250 Ga.App. 187 (2001) (illustrates evidentiary weight considerations in new-trial context)
- Hill v. State, 254 Ga.2d 213 (1985) (fingerprint evidence admissibility and lack of chain-of-custody impact on weight, not admissibility)
- Chapel v. State, 270 Ga. 151 (1998) (high materiality standard for newly discovered evidence in new-trial motions)
- Rivers v. State, 271 Ga. 115 (1999) (fingerprint evidence reliability and probative value)