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Young v. State
290 Ga. 441
| Ga. | 2012
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Background

  • 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)
Read the full case

Case Details

Case Name: Young v. State
Court Name: Supreme Court of Georgia
Date Published: Jan 9, 2012
Citation: 290 Ga. 441
Docket Number: S11A1296
Court Abbreviation: Ga.