Wright v. State
314 Ga. App. 353
Ga. Ct. App.2012Background
- Wright was convicted of aggravated assault with intent to rape, attempted rape, false imprisonment, simple battery, and simple assault.
- He moved for new trial; the trial court denied after a hearing, and Wright appeals.
- Evidence showed the victim was followed, knocked down, dragged toward a vacant lot, and restrained, with wounds and clothing displaced.
- Blood analysis on the victim’s sweatshirt linked Wright to the attack.
- A prior juvenile offense involving a nine-year-old victim occurred when Wright was fourteen, which the State sought to admit as similar transaction evidence.
- The appellate court affirmed the convictions, finding the evidence sufficient and the similar-transaction evidence admissible.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for aggravated assault and attempted rape | Wright contends no intent to rape shown; insufficient substantial step. | State argues circumstantial evidence supports intent and substantial step. | Evidence sufficient to support convictions. |
| Admissibility of similar transaction evidence | State failed to prove similarity between prior offense and current case. | Similarity established by totality of similar facts; admissible especially in sexual offenses. | Similar transaction evidence admissible; not clearly erroneous. |
Key Cases Cited
- Jackson v. State, 252 Ga.App. 268 (2001) (view evidence in light favorable to support verdict)
- Butler v. State, 194 Ga.App. 895 (1990) (intent may be inferred from circumstances; circumstantial proof allowed)
- Helton v. State, 166 Ga.App. 662 (1983) (circumstantial evidence can support intent)
- De'Mon v. State, 262 Ga.App. 10 (2003) (reasonable hypotheses exclusion; jury determination)
- Condra v. State, 238 Ga.App. 174 (1999) (similar transaction evidence in sexual offenses)
- Payne v. State, 285 Ga. 137 (2009) (liberal admissibility of similar transactions in sex offenses)
- Kingsley v. State, 268 Ga.App. 729 (2004) (age differences alone not determinative of similarity)
- Smith v. State, 206 Ga.App. 557 (1992) (prior transactions sufficiently similar despite age difference)