Hatney v. State

841 S.E.2d 702, 308 Ga. 438
CourtSupreme Court of Georgia
DecidedApril 6, 2020
DocketS20A0202
StatusPublished
Cited by7 cases

This text of 841 S.E.2d 702 (Hatney 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
Hatney v. State, 841 S.E.2d 702, 308 Ga. 438 (Ga. 2020).

Opinion

308 Ga. 438 FINAL COPY

S20A0202. HATNEY v. THE STATE.

ELLINGTON, Justice.

Following a jury trial, Cornelius Hatney was convicted of

felony murder predicated on aggravated assault in connection with

the beating death of Etate Essang. Hatney appeals, contending that

the trial court erred in refusing to give a requested jury instruction

on voluntary manslaughter as a lesser offense of the charges of

malice murder and felony murder. For the reasons set forth below,

we affirm Hatney’s conviction.1

1 The crimes occurred on October 10, 2008. On May 1, 2009, a Lowndes

County grand jury returned an indictment charging Hatney with malice murder, felony murder (predicated on aggravated assault), and aggravated assault. Following a jury trial ending on August 3, 2010, Hatney was found not guilty of malice murder and guilty of felony murder and aggravated assault. The trial court sentenced Hatney to life imprisonment for felony murder. The sentencing order indicated that aggravated assault merged with the felony murder conviction. On August 31, 2010, Hatney filed a timely motion for a new trial, which he amended on February 25, 2016. Following a hearing on September 16, 2016, the trial court denied Hatney’s motion for a new trial on July 21, 2017, and Hatney filed a timely notice of appeal. The case was docketed in this Court for the term beginning in December 2019 and orally argued on January 16, 2020. Viewed in the light most favorable to the verdict,2 the evidence

presented at trial showed the following. On October 10, 2008, an

inmate who was in the day room at Valdosta State Prison saw

Hatney — who was known as “Little Swoll” because of his size and

build — Essang, and a few other inmates go into a cell on the lower

level of the split-level dormitory. The inmate heard sounds of a

scuffle emanating from the cell. After a few minutes, it got quiet.

Then Hatney dragged Essang out of the cell by his feet; Essang was

wrapped in a sheet. Hatney dragged Essang up the steps to the day

room, laid him down and, while wearing boots, jumped on his head.

Hatney repeatedly kicked Essang in the head and hit him in the

head several times with a garbage can lid. Throughout this attack,

according to several inmates, Hatney screamed, “he was jacking on

me.” At trial, an inmate explained that the term “jacking” means

masturbating.

After hearing a loud noise, a correctional officer went to

2 See Jackson v. Virginia, 443 U. S. 307, 319 (99 SCt 2781, 61 LE2d 560)

(1979). investigate. When he entered the dormitory, he saw Hatney kicking

Essang, who was lying face down on the floor, motionless. Hatney

yelled to the officer, “he was jacking on me.” The officer ordered

Hatney to stop kicking Essang, and he put himself between the two

inmates. The officer called for backup and medical assistance. When

other officers arrived, Hatney submitted to being handcuffed.

One of the officers responding to the call for backup brought a

video camera and recorded the events as a nurse checked on

Essang’s condition. Essang’s feet were tied with a piece of towel, and

his hands were tied with strips of a sheet. When the staff rolled

Essang’s body over, his face “looked like hamburger,” as described

by one officer. The shift supervisor noticed that Essang’s eyes were

out of alignment, suggesting that he had sustained serious head

trauma, so the supervisor called for an ambulance and directed staff

members to take Essang to the infirmary. Medical staff found that

Essang had several deep vertical cuts on his back and buttocks.

Three officers escorted Hatney to the segregation unit. One of

the officers walked behind Hatney and used the video camera to record Hatney’s behavior en route. The video-recording was played

at trial, and all three officers testified regarding Hatney’s

statements. The video-recording shows that Hatney spontaneously

told the officers that he “did it” because Essang was “trying to jack

his d*ck off me.” Hatney said that the incident began when he

caught Essang spying on him in the shower. Hatney stated that he

pulled back the shower curtain and demanded to know what Essang

was doing. According to Hatney, Essang responded, “You know what

I’m doing. . . . I’m going to try you on some gay sh*t.” Hatney stated

that he told Essang to “stay right there,” put on his boots,3 knocked

Essang out with one punch, tied him up, and dragged him “up and

down” the steps. An officer asked how Essang got the cuts on his

back side, and Hatney said the cuts probably came from him

dragging Essang across the sharp edge of the steps and over railings.

Hatney volunteered repeatedly that he beat Essang because Essang

was “jacking” on him, and Hatney was not “about [any] homosexual

3 Hatney did not specify when he got dressed after showering, but the

video recording shows that he was dressed when the first correctional officer intervened. stuff.” He likened Essang’s conduct to an attempted sexual assault.

Hatney said he “straighten[ed] him out,” and “did it for all the young

folks” that might come into the prison so that, if Essang, who was

over six feet tall, lived, he would never again “try [anybody who was]

weak” or “short” with any “gay sh*t,” because he would know that

they “might do how Little Swoll did.” Hatney claimed that he was

also showing the rest of the inmates that they should not disrespect

him like Essang had done. After being advised of his Miranda4

rights, Hatney agreed to answer questions; he continued to insist

that “he did it because the dude was jacking on him.”

After a month in the hospital, Essang succumbed to his injuries

and died from complications of blunt force trauma to the head.

Hatney was charged with committing malice murder, felony

murder, and aggravated assault by striking Essang with a trash can

lid and kicking Essang with his feet, “objects which when used

offensively against a person, in the manner then and there used,

4 Miranda v. Arizona, 384 U. S. 436 (86 SCt 1602, 16 LE2d 694) (1966). [are] likely to result in serious bodily injury[.]”5

1. Hatney does not challenge the sufficiency of the evidence.

Nevertheless, as is our customary practice in murder cases, we have

independently reviewed the record and conclude that the evidence

presented at trial was legally sufficient to authorize a rational trier

of fact to find beyond a reasonable doubt that he was guilty of felony

murder. See Jackson v. Virginia, 443 U. S. 307, 319 (99 SCt 2781,

61 LE2d 560) (1979).

2. Hatney contends that the trial court erred when it refused

to give a requested pattern jury instruction on voluntary

manslaughter as a lesser offense of both malice murder and felony

murder predicated on aggravated assault. Voluntary manslaughter

is the killing of another person under circumstances that would

otherwise be murder when the killer

acts solely as the result of a sudden, violent, and irresistible passion resulting from serious provocation sufficient to excite such passion in a reasonable person;

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841 S.E.2d 702, 308 Ga. 438, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hatney-v-state-ga-2020.