Carson v. State

843 S.E.2d 421, 308 Ga. 761
CourtSupreme Court of Georgia
DecidedMay 18, 2020
DocketS20A0288
StatusPublished
Cited by14 cases

This text of 843 S.E.2d 421 (Carson 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
Carson v. State, 843 S.E.2d 421, 308 Ga. 761 (Ga. 2020).

Opinion

308 Ga. 761 FINAL COPY

S20A0288. CARSON v. THE STATE.

ELLINGTON, Justice.

Anderson Carson was tried before a Fulton County jury and

convicted of the malice murder of Lee Sokol and the robbery by force

of Fred Hickson.1 Carson contends on appeal that the trial court

erred in (1) denying his motion to sever, (2) appearing to assist the

State in its prosecution by recommending that the State procure

material witness warrants, (3) permitting the introduction into

1 The crimes occurred on June 8 and 9, 2009. On February 9, 2010, Carson was indicted for the malice murder, felony murder predicated on aggravated assault, and aggravated assault of Sokol. In the same indictment, Carson was charged with the robbery by force and battery of Fred Hickson. Carson was tried before a jury in January 2011. The jury found Carson guilty of malice murder, felony murder, aggravated assault, and robbery by force, and not guilty of battery. The trial court sentenced Carson to life imprisonment for malice murder and to a consecutive sentence of ten years for robbery by force. The count of aggravated assault merged with the count of malice murder. The trial court indicated that the count of felony murder merged with the count of malice murder, although the felony murder was actually vacated by operation of law. See Lucky v. State, 286 Ga. 478, 480 (2) (689 SE2d 825) (2010). Carson filed a timely motion for new trial, which he amended on September 6, 2013. The trial court denied the motion on February 8, 2019. Carson filed a timely notice of appeal, and his appeal was docketed to the term beginning in December 2019 and submitted for decision on the briefs. evidence of Carson’s prior conviction for aggravated assault, (4)

allowing the State to introduce into evidence a booking photograph

without providing the photograph to the defense in accordance with

the State’s discovery obligations, (5) denying his motion to exclude

his statements to a police detective, (6) denying his motion to

suppress, and (7) failing to strike a prospective juror for cause.

Carson also contends that the evidence was insufficient to support

the jury’s verdicts. We affirm for the reasons set forth below.

Viewed in the light most favorable to the jury’s verdicts, the

evidence presented at trial shows the following. On the morning of

June 9, 2009, a teacher at E. Rivers Elementary School in Atlanta

looked out of his classroom window and saw a man’s body lying in

the courtyard. City of Atlanta police officers responded to the scene

around 7:30 a.m. The decedent, later identified as Sokol, had

suffered severe head wounds. A bloody rock was lying two to three

feet away from the body.

Detective William Murdock noticed that cameras had been

placed around the school and asked Atlanta Public Schools for a copy of the video. After speaking with the teacher who discovered the

body, Murdock and other officers canvassed the school and nearby

areas but were unable to locate any additional witnesses.

Later in the day, Detective Murdock attended the autopsy of

the victim. The medical examiner determined that Sokol had died

from blunt force injuries to the head. While Detective Murdock was

at the medical examiner’s office, he received a report that Carson

had been arrested at approximately 12:15 a.m. the night before near

Piedmont Hospital on a charge of robbery of a pedestrian. That

location was less than a mile from the elementary school. The

sequence of violent crimes stood out to Detective Murdock because

those types of crime were rare in that area of the city.

Detective Murdock arranged for the Fulton County sheriff to

have Carson remanded to his custody for purposes of an interview,

which occurred on June 9. Before the interview, Detective Murdock

received two video images recorded by the school’s cameras. One

frame, taken at 10:43 p.m. on June 8, showed a man wearing all

black clothing, white shoes, and carrying a light colored bag. The other image, time stamped 10:48 p.m., showed another man wearing

long dark or blue shorts and a hooded sweatshirt.

During the interview, Detective Murdock read Carson his

Miranda2 rights. Carson then denied having been anywhere near

the elementary school. Carson also said that he had been wearing

jean shorts and a “hoodie sweatshirt” on the night of his arrest.

Detective Murdock applied for and obtained a search warrant for the

clothes Carson had been wearing when he was arrested. A GBI

forensic analyst testified that DNA obtained from blood on Carson’s

clothes, as well as from the rock found at the scene, originated from

Sokol.

Three days after interviewing Carson, Detective Murdock

received 12 hours of video recordings from the elementary school’s

security cameras. Portions of the video recordings were played for

the jury at trial. None of the cameras had been pointed at the

courtyard area where Sokol’s body was found. However, a man

wearing long shorts and a light-colored hooded sweatshirt was

2 Miranda v. Arizona, 384 U. S. 436 (86 SCt 1602, 16 LE2d 694) (1966). shown entering the school property after 10:39 p.m. A second man,

dressed in black clothes and wearing white tennis shoes, was seen

at 10:43 p.m. walking into the courtyard and off camera. The second

man’s clothing matched that worn by Sokol. The man wearing a

hood walked in and out of the view of the cameras several times,

including walking into and out of the courtyard area. The man with

the hood was last seen on the school’s video at 11:31 p.m.

The State also presented evidence of the robbery that occurred

the night before Sokol’s body was discovered. In the early morning

of June 9, 2009, Fred Hickson and his cousin left Piedmont Hospital

and waited for their cab to arrive. Carson came from behind Hickson

and punched him in the face. After Hickson turned around in shock,

Carson took Hickson’s jacket and ran. Hickson and his cousin ran

after Carson, who picked up a brick and confronted the two men.

A City of Atlanta police officer was driving by Piedmont

Hospital shortly after midnight on June 9 when he saw Hickson and

his cousin chasing Carson through the parking lot. The officer

stopped the two cousins, and then Carson. Carson was arrested and taken to jail. Hickson’s jacket was recovered at the scene.

The State also introduced evidence of a similar transaction.

Jory Hardin testified that on December 1, 2003, he was working as

a uniformed police officer with the Metropolitan Atlanta Rapid

Transit Authority. When Officer Hardin opened the Civic Center

station at 4:00 that morning, Carson hit Officer Hardin in the head

with a brick.

1. Carson claims that the evidence was insufficient for a

rational trier of fact to find him guilty beyond a reasonable doubt of

the malice murder, felony murder, and aggravated assault of Sokol

because the State relied on circumstantial evidence which did not

exclude all reasonable hypotheses other than his guilt.

Under both former OCGA § 24-4-6, in effect at the time of [Carson’s] trial, and present OCGA § 24-14-6

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843 S.E.2d 421, 308 Ga. 761, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carson-v-state-ga-2020.