Casey v. State

310 Ga. 421
CourtSupreme Court of Georgia
DecidedNovember 12, 2020
DocketS20A1105
StatusPublished
Cited by7 cases

This text of 310 Ga. 421 (Casey 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
Casey v. State, 310 Ga. 421 (Ga. 2020).

Opinion

310 Ga. 421 FINAL COPY

S20A1105. CASEY v. THE STATE.

BETHEL, Justice.

A Lowndes County jury found Clarence Casey guilty of felony

murder predicated on an aggravated assault and possession of a

firearm during the commission of a felony in connection with the

shooting death of Alfred Pierre Bradley. Following the denial of his

motion for new trial, Casey appeals, alleging that the State

presented insufficient evidence to support the jury’s verdict, the trial

court did not apply the proper standard in evaluating Casey’s claim

for relief on the “general grounds” set forth in OCGA §§ 5-5-20 and

5-5-21, and the trial court erred by admitting certain evidence.

While there was sufficient evidence to support the verdict as a

matter of due process, we conclude that the trial court failed to

exercise its discretion as the “thirteenth juror” under OCGA §§ 5-5- 20 and 5-5-21 in ruling upon Casey’s motion for new trial.1 We

therefore vacate the trial court’s order in part and remand the case

to the trial court. We do not reach Casey’s final enumeration of error

in this appeal.

1. Viewed in the light most favorable to the verdict, the evidence

presented at trial showed the following. In the early morning of

January 13, 2013, Bradley drove his car to a store in Lowndes

County. He exited his car and walked into the store. Casey, Radcliffe

Eady, and Michael Green were standing outside the store. When

Bradley exited the store, Eady ran toward Bradley with a .45-caliber

1 The crimes occurred on January 13, 2013. Casey was indicted by a

Lowndes County grand jury on April 26, 2013, for malice murder (Count 1); felony murder (Count 2); aggravated assault (Count 3); possession of a firearm during the commission of a felony (Count 4); and possession of a firearm by a convicted felon (Count 5). A jury trial was held on January 27, 28, and 30, 2014, and the jury found Casey not guilty on Count 1 but guilty on Counts 2, 3, and 4. The trial court entered an order of nolle prosequi as to Count 5. Casey was sentenced to serve life in prison without parole for felony murder, and the aggravated assault count was merged into the felony murder count. Casey was also sentenced to five years consecutive for possession of a firearm during the commission of a felony. Casey filed a timely motion for new trial on March 11, 2014, which he amended on May 2, 2019. The trial court entered an order denying the motion on August 20, 2019. Casey filed a timely notice of appeal. This case was docketed in this Court to the August 2020 term and submitted for a decision on the briefs. 2 pistol. The two struggled over the firearm, and Bradley eventually

obtained control of it. During this struggle, the pistol fired, and

Bradley then ran around the side of the building.

Bradley was highly agitated and returned to the front of the

building waving the gun, “screaming, and yelling.” Casey, a

convicted felon armed with a firearm, approached Bradley from

behind and shot him at close range in the back of the head. Casey,

still in possession of the gun he used to shoot Bradley, walked away.

At some point following the incident, Casey apologized to the owner

of the establishment for shooting Bradley at her store.

On January 15, 2013, during a custodial police interrogation

and after receiving Miranda warnings,2 Casey agreed to answer

questions. Casey initially said that he was not at the store at all on

the day the crime occurred. He later admitted that he was at the

store but said that he was not there when the shooting occurred, and

he denied shooting Bradley.

2 See Miranda v. Arizona, 384 U. S. 436 (86 SCt 1602, 16 LE2d 694)

(1966). 3 Following an autopsy, the forensic pathologist determined that

a gunshot wound to the head caused Bradley’s death and ruled the

death a homicide. The entrance wound, located on the left side of the

back of Bradley’s head, had a partial muzzle imprint, meaning that

the gun’s muzzle was in contact with the skin at the time it was

fired.

Casey argues that the evidence was insufficient to support the

jury’s verdict because, even when viewed in the light most favorable

to the verdict, no rational trier of fact could have found Casey guilty

beyond a reasonable doubt of felony murder and possession of a

firearm during the commission of a felony. We disagree.

When evaluating the sufficiency of evidence as a matter of

federal due process under the Fourteenth Amendment to the United

States Constitution, the proper standard of review is whether a

rational trier of fact could have found the defendant guilty beyond a

reasonable doubt. See Jackson v. Virginia, 443 U. S. 307, 319 (III)

(B) (99 SCt 2781, 61 LE2d 560) (1979). This Court views the evidence

in the “light most favorable to the verdict, with deference to the

4 jury’s assessment of the weight and credibility of the evidence.”

(Citation and punctuation omitted.) Hayes v. State, 292 Ga. 506, 506

(739 SE2d 313) (2013).

Casey was convicted of felony murder predicated on

aggravated assault and possession of a firearm during the

commission of a felony. Although the trial court properly merged the

aggravated assault count for sentencing, we must consider whether

the evidence presented at trial was sufficient to support a finding

that Casey committed the alleged aggravated assault because it was

the predicate felony for the felony murder.

OCGA § 16-5-1 (c) provides that “[a] person commits the offense

of murder when, in the commission of a felony, he or she causes the

death of another human being irrespective of malice.” OCGA § 16-5-

21 (a) provides, in relevant part, that “[a] person commits the offense

of aggravated assault when he or she assaults . . . [w]ith a deadly

weapon or with any object, device, or instrument which, when used

offensively against a person, is likely to or actually does result in

serious bodily injury[.]” OCGA § 16-11-106 (b) (1) provides, in

5 relevant part, that “[a]ny person who shall have on or within arm’s

reach of his or her person a firearm . . . during the commission of, or

the attempt to commit[,] . . . [a]ny crime against or involving the

person of another . . . and which crime is a felony, commits a

felony[.]”

Eyewitness testimony established that Casey shot Bradley in

the head at close range. Forensic evidence supported this testimony

by showing that Bradley was fatally shot in the back of the head by

a gun in contact with his scalp. Moreover, Casey later apologized to

the shop owner for shooting Bradley, and he gave inconsistent

accounts to the police. This evidence was sufficient as a matter of

due process to authorize a rational trier of fact to find Casey guilty

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