Young v. State
290 Ga. 441
| Ga. | 2012Background
- Appellant Kareem K. Young was convicted of felony murder and related offenses for the death of Arkeem Lavan Young.
- The shooting occurred around midnight in the driveway of the victims’ home; Arkeem was killed after a confrontation; officers responded quickly to a 911 call.
- Appellant gave a false name and an inconsistent account, claiming a black truck fired the shot, which the police could not corroborate.
- Shell casing and blood spatter placed the gun at a location inconsistent with a street-fired shot; gunpowder residue on appellant’s hands supported intent or involvement.
- A handgun later recovered under the house was stolen and linked to both this murder and a prior convenience-store homicide; appellant was a suspect in the latter.
- The trial court admitted similar-transaction evidence linking the gun to both crimes, and issues of potential witness-bias and jury viewing were considered on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady materiality of the management report | Young argues the report is favorable impeachment material. | State contends report is non-material and inadmissible hearsay. | Report not material; not exculpatory or impeaching; no Brady error. |
| Failure to identify a witness from the convenience-store shooting | State withholding potentially exculpatory witness statement. | Statement reviewed in camera showed no exculpation. | No error; statement not exculpatory. |
| Admission of 2004 convenience-store homicide as similar-transaction evidence | Prosecutor linked the gun and defendant to both crimes. | Sufficient connection shown between gun, crimes, and appellant. | No abuse; sufficient connection established. |
| Cross-examination of Officer Nollinger for bias | Defense sought broad cross-exam on bias due to other proceedings. | Constitution tolerates reasonable limits on cross-examination. | Trial court did not abuse discretion; limits justified. |
| Right to a jury view denied | A jury view would aid understanding of scene. | Video, diagrams, and photographs sufficed. | No abuse; view unnecessary and potentially problematic. |
Key Cases Cited
- United States v. Bagley, 473 U.S. 667 (1985) (materiality standard for Brady evidence: reasonable probability of different outcome)
- Kyles v. Whitley, 514 U.S. 419 (1995) (Brady requires materiality, not every favorable item constitutes Brady material)
- Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency of evidence standard for conviction)
- United States v. Bartholomew, 516 U.S. 1 (1995) (admissibility and hearsay considerations affecting evidence disclosure)
- Watkins v. State, 276 Ga. 578 (2003) (Confrontation Clause limits on cross-examination; reasonableness standard)
- Sapp v. State, 263 Ga. App. 122 (2003) (cross-examination and bias assessment; appellate comparison)
- Esposito v. State, 273 Ga. 183 (2000) (jury view and trial evidence considerations)
- Malcolm v. State, 263 Ga. 369 (1993) (scope of admissibility of similar-transaction evidence)
- Young v. State, 281 Ga. 750 (2007) (precedent for admissibility of similar-transaction evidence in Georgia)
