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Wright v. State
296 Ga. 276
Ga.
2014
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Background

  • In 2008, Wright and two accomplices robbed Lard; Brown fired a shot and one firearm casing linked to subsequent crimes was recovered.
  • On June 20, 2008, Wright and Brown targeted four Hispanic men for a robbery; Brown carried a .40 caliber pistol and participated in the attempted robbery.
  • During the encounter in Sedona Falls, Carbajal was shot and killed by Brown; Wright drove away after signaling Brown and Stokes to return to the car.
  • Mora and Turner pursued Wright’s car; Turner confronted the occupants; a .40 caliber pistol recovered later matched the cartridge at the Lard and Carbajal scenes.
  • Brown later testified about Wright’s involvement; at Wright’s trial, Brown claimed Wright had foreknowledge, while at a prior hearing he testified differently.
  • Stokes, who pled guilty to murder and armed robbery, testified at Wright’s trial but claimed his pleas were coerced; his plea transcript was read to impeach him.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Admission of 2004 Norris incident evidence Norris act used to prove character; improper under 404(b). Similar acts show course of conduct and bent of mind; admissible. Court did not abuse discretion; similarities supported admissibility.
Use of Stokes plea transcript for impeachment Premature or improper; violates confrontation rights. Transcript admissible under impeachment and refreshment rules. Admissible under 24-9-82; confrontation issue not preserved.
Sufficiency of evidence to support guilt No direct identification; insufficient for PW credibility. Eyewitness testimony and party liability support conviction. Evidence sufficient to convict; jury credibility preserved.
Effective assistance of counsel Counsel failed to call witnesses and introduce certain records. No showing of prejudice; strategic decisions reasonable. No reversible error; defense lacked demonstrated prejudice.

Key Cases Cited

  • Johnson v. State, 289 Ga. 106 (2011) (prior inconsistent statements admissible; no denial requirement)
  • Wilkins v. State, 291 Ga. 483 (2012) (impeachment standards for former statements; coherence with 24-9-82)
  • Mathis v. State, 279 Ga. 100 (2005) (affirmative standard for admitting evidence; Bruton rationale)
  • Hall v. State, 292 Ga. 701 (2013) (preservation and waiver of evidentiary objections)
  • Bruton v. United States, 391 U.S. 123 (1968) (inadmissibility of antagonist statements in joint trial)
  • Boykin v. Alabama, 395 U.S. 238 (1969) (requirements for knowing, voluntary, intelligent guilty plea)
  • State v. Evans, 265 Ga. 332 (1995) (plea transcript impeachment limitations and redaction considerations)
Read the full case

Case Details

Case Name: Wright v. State
Court Name: Supreme Court of Georgia
Date Published: Nov 24, 2014
Citation: 296 Ga. 276
Docket Number: S14A0602
Court Abbreviation: Ga.