Byers v. State

857 S.E.2d 447, 311 Ga. 259
CourtSupreme Court of Georgia
DecidedApril 5, 2021
DocketS21A0296
StatusPublished
Cited by18 cases

This text of 857 S.E.2d 447 (Byers v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Byers v. State, 857 S.E.2d 447, 311 Ga. 259 (Ga. 2021).

Opinion

311 Ga. 259 FINAL COPY

S21A0296. BYERS v. THE STATE.

PETERSON, Justice.

Christopher Byers appeals his convictions for malice murder,

aggravated battery, concealing the death of another, abandonment

of a dead body, and tampering with evidence, all related to the

killing of Ray Walnoha.1 Byers’s primary enumeration of error is

that the trial court erred by excluding inculpatory statements by

1 Walnoha was killed sometime in late July 2014. On December 7, 2016,

a Pickens County grand jury indicted Byers and Arnold Griffith, Jr., for malice murder and other crimes. On February 2, 2018, the grand jury returned a new indictment of Byers alone, charging him with malice murder, three counts of felony murder, three counts of aggravated assault, aggravated battery, concealing the death of another, abandonment of a dead body, and four counts of tampering with evidence. After a trial held from July 30 through August 6, 2018, a jury found Byers guilty on all counts. On August 6, 2018, the trial court sentenced Byers to life in prison for malice murder, along with concurrent prison sentences of twenty years for aggravated battery, five years for concealing the death of another, three years for abandonment of a dead body, and five years for tampering with evidence. The felony murder counts were vacated by operation of law, and the trial court merged the remaining counts. Byers filed a motion for new trial on August 17, 2018, and amended the motion on February 24, 2020. Following a hearing, the trial court denied the motion in an order entered on August 10, 2020. Byers filed a timely notice of appeal on August 18, 2020, and the case was docketed to this Court’s term beginning in December 2020 and submitted for a decision on the briefs. another man involved in the crimes, overheard by a defense witness.

Byers also argues that his conviction for aggravated battery was not

supported by sufficient evidence, and that, alternatively, that count

should have merged into his malice murder conviction, and that his

sentence for the crime of tampering with evidence should have been

that of a misdemeanor. We agree that the tampering count should

have been treated as a misdemeanor, and so we vacate Byers’s

conviction on that count and remand the case for resentencing. We

conclude that any error in failing to admit the defense witness

testimony at issue was harmless, and that the evidence was

sufficient to support a conviction for aggravated battery on which

the trial court properly entered a separate sentence, and we

therefore affirm Byers’s other convictions.

Byers’s convictions are predicated on evidence that he killed

Walnoha with an ax at the Pickens County home of Arnold Griffith,

Jr. The killing occurred sometime in late July 2014. Walnoha’s body

was never found.

After Byers was taken into custody on an unrelated warrant in

2 the fall of 2016, he admitted to an investigator that he twice struck

Walnoha in the head with an ax while Walnoha slept on a couch on

Griffith’s porch, claiming that Walnoha intended to kill and rob

Griffith and his family. Byers claimed that he then told Griffith that

Walnoha was dead; Walnoha was still alive, however, having

managed to crawl into the yard. After finding Walnoha in the yard,

Byers claimed, Griffith struck Walnoha with the ax in the back of

the neck. Byers admitted that he buried Walnoha’s body in the

woods with Griffith, cleaned up the crime scene, and took Walnoha’s

car, while Griffith cleaned off the ax. Byers also made incriminating

statements to fellow inmates; one inmate testified that Byers told

him that Walnoha was “twitching” or “kind of convulsing” when

Byers and Griffith found him in the yard.

Griffith, who pleaded guilty to various charges related to

Walnoha’s death prior to Byers’s trial, testified that, on the day

Walnoha was killed, Byers summoned him to look out into the yard,

where, Byers reported, Walnoha was “dying.” Griffith testified that

he observed that Walnoha was sitting in the yard, “swaying.”

3 Griffith testified that he told Byers he would have to “do something”

and then looked away, whereupon he heard what he presumed to be

the sound of Byers killing Walnoha with an ax. Griffith admitted

that he helped Byers clean up the crime scene, including using

bleach on the porch, cleaning off the ax, and burying the body in the

woods nearby. Griffith testified that Byers later told Griffith that he

had moved the body but did not say where.

Byers’s admissions and Griffith’s statements as to Byers’s

involvement in Walnoha’s death were corroborated by other

evidence. On July 23, 2014, Byers’s sister and mother saw Walnoha

and Byers together in Walnoha’s car. Sometime in the next few days,

Byers’s mother saw Byers driving Walnoha’s car. Byers showed his

mother that he had Walnoha’s wallet, driver’s license, and cell

phone, and reported that Walnoha had given him the car and was

with his girlfriend in Tennessee. Byers, who was acting strangely,

showed his mother what she called a “hatchet” that was in the trunk

of the car. On July 28, 2014, Walnoha’s car was involved in an

accident and found abandoned about two miles from the crash site.

4 Byers’s DNA was recovered from blood on the driver’s side airbag of

the car.

Several months after Walnoha disappeared, Byers visited

Walnoha’s brother and the brother’s girlfriend, telling her, “I don’t

think you’ll ever have to worry about Ray knocking on the door

again.” In March 2016, Byers asked Walnoha’s sister for help with

legal trouble involving a car accident, asking her to testify that

Walnoha never let anyone drive his car. Byers told the sister that

her brother had met “some girl” and was in Kentucky.

The investigation into Walnoha’s disappearance was sparked

in earnest in May 2016 when sheriff’s deputies visited Griffith’s

home while investigating an unrelated matter. William

Bartlebaugh, who was staying at Griffith’s house, showed deputies

a purported burial site near the home. Griffith also went with police

and identified a place on a trail near the home as the place where

Walnoha had been buried. A cadaver dog alerted to the same

location. In a nearby burn barrel, agents found small bones,

consistent with finger or foot bones, but too small for agents to test

5 for DNA or even determine whether they were human remains.

Agents also saw an area of the ground that appeared to have been

disturbed, consistent with a very shallow grave.

GBI agents found that floorboards of a porch on Griffith’s house

had been bleached and that a wall was discolored and tested positive

for the presence of blood. Inside the house, agents found a license

plate that matched Walnoha’s car. They also collected an ax from

the nearby home of Griffith’s sister, Marjorie Babcock, that matched

the description of the murder weapon later given by Byers.

After his arrest in the fall of 2016, Byers identified as

Walnoha’s burial site the same place near Griffith’s home that

Griffith and the cadaver dog had identified.

1. Byers first argues that the trial court erred in excluding

evidence proffered by the defense that Griffith had admitted killing

Walnoha. We conclude that any error in this evidentiary ruling was

harmless.

The defense proffered that Griffith’s brother-in-law, Wesley

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857 S.E.2d 447, 311 Ga. 259, Counsel Stack Legal Research, https://law.counselstack.com/opinion/byers-v-state-ga-2021.