Younger v. State
288 Ga. 195
| Ga. | 2010Background
- Younger is convicted of felony murder and possession of a firearm during the commission of a felony for the death of Scott Monty during a plan to rob a drug dealer.
- Court evidence shows a group planned the robbery; Younger allegedly took Freeman's pistol and assisted in entering Monty's home.
- Monty confronted the intruders; a struggle ensued and Younger fatally shot Monty as he reached for Younger's pistol.
- Younger argued abandonment of the robbery plan, but he did not request an abandonment instruction and the record shows he left in response to being confronted, not a voluntary renunciation.
- During trial, Younger challenged jury composition under Batson and cross-examined a co-indictee with limited success; Brady and impeachment issues were also raised.
- The trial court denied Younger’s post-trial motions; the Supreme Court of Georgia affirmed the convictions on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for felony murder predicate | Younger abandoned attempt but argues abandonment negates the predicate crime | Abandonment not shown; conduct not voluntary renunciation under OCGA 16-4-5 | Evidence sufficient to support felony murder verdict |
| Batson challenge on peremptory strikes | State discriminatorily struck two African-American venire members | State provided race-neutral explanations for strikes; trial court found no error | Trial court properly evaluated race-neutral explanations; no reversible Batson error |
| Cross-examination of immunity witness regarding bond | Should have probed potential bias from bond agreement with immunity | Court properly limited cross-examination for relevance and safety | Limitations were reasonable; harmless beyond a reasonable doubt |
| Brady/Giglio impeachment disclosure regarding Freeman | State failed to disclose any deal with Freeman; bias impeachment evidence | No agreement or favorable deal existed; no Brady violation | No Brady violation; no undisclosed favorable evidence affecting outcome |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review requires no reasonable doubt)
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (three-step framework for race-based peremptory challenges)
- Hanifa v. State, 269 Ga. 797 (Ga. 1998) (abandonment requires voluntary and complete renunciation)
- Crowder v. State, 268 Ga. 517 (Ga. 1997) (confrontation and limits on cross-examination; discretion of trial court)
- Vogleson, 275 Ga. 637 (Ga. 2002) (harmless error analysis for evidentiary restrictions)