Hayes v. State

910 S.E.2d 198, 320 Ga. 505
CourtSupreme Court of Georgia
DecidedDecember 10, 2024
DocketS24A1354
StatusPublished
Cited by7 cases

This text of 910 S.E.2d 198 (Hayes 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
Hayes v. State, 910 S.E.2d 198, 320 Ga. 505 (Ga. 2024).

Opinion

320 Ga. 505 FINAL COPY

S24A1354. HAYES v. THE STATE.

BOGGS, Chief Justice.

Appellant Jarrod James Hayes challenges his convictions for

malice murder and other crimes in connection with the shooting

death of Zedekiah Jones. Appellant contends that the trial court

erred in denying his motion to suppress three firearms that were

discovered at his home after he disclosed their existence and location

in a statement that was not preceded by warnings required by

Miranda.1 He also asserts that he was denied the effective

assistance of counsel; that the trial court abused its discretion by

allowing a witness’s video-statement to be played after the witness

claimed not to recall the statement; that the trial court erred by

refusing to bifurcate his malice murder and aggravated assault

counts from his three felon-in-possession counts; that the trial court

erred by refusing to give jury instructions on voluntary

1 Miranda v. Arizona, 384 U.S. 436 (86 SCt 1602, 16 LE2d 694) (1966). manslaughter and mutual combat; and that the combined

prejudicial effect of the multiple errors of the trial court and multiple

deficiencies of trial counsel requires a new trial. We conclude that

because the statement given without Miranda warnings was

voluntary, the firearms were admissible. We also conclude, for the

reasons set forth below, that his other claims fail. Accordingly, we

affirm.2

1. The evidence presented at trial showed the following.3 On

2 The crimes occurred on January 17, 2020. On January 31, 2020, a Douglas County grand jury indicted Appellant for malice murder, aggravated assault, two counts of felony murder, three counts of possession of a firearm by a convicted felon, and possession of less than an ounce of marijuana. The marijuana-possession count was nolle prossed, and at a trial from February 15 to 22, 2022, the jury found Appellant guilty of all charges. The trial court sentenced Appellant to serve life in prison without the possibility of parole for malice murder and three terms of five years imprisonment each for the weapons charges, running concurrently with each other. The felony murder verdicts were vacated by operation of law, and the trial court merged the aggravated assault count into the malice murder conviction. On March 14, 2022, Appellant timely filed a motion for new trial, which he amended with new counsel on April 24, 2023. After an evidentiary hearing on June 22, 2023, the trial court entered an order denying the motion on May 9, 2024. Appellant filed a timely notice of appeal, and the case was docketed in this Court to the August 2024 term and submitted for a decision on the briefs. 3 Because this case involves questions of harmless error and prejudice

under Strickland v. Washington, 466 U.S. 668 (104 SCt 2052, 80 LE2d 674) (1984), we set out the evidence in detail, rather than recounting it in the light most favorable to the jury’s verdicts. See Moore v. State, 315 Ga. 263, 264 n.2 (882 SE2d 227) (2022). 2 January 16, 2020, Zedekiah Jones and his wife, McKeda Jones,

traveled from Utah to Atlanta, Georgia, for Zedekiah’s

grandmother’s funeral. When they arrived in Atlanta, they rented a

car at the airport, went shopping, and then drove to Quincy Sims’s

father’s home near the West End neighborhood. Sims and Zedekiah

had been friends for several years. While at Sims’s home, Zedekiah,

McKeda, Sims, and other friends and family were “drinking and

barbecuing.” Zedekiah, McKeda, and Sims remained there until

around 11:00 p.m., at which point they decided to go “holler at”

Appellant, who lived in Douglasville, Georgia. Zedekiah, Sims, and

Appellant had all been friends for several years. Zedekiah, McKeda,

and Sims arrived at Appellant’s home on Viola Court in Douglas

County between 11:00 p.m. and midnight. When they arrived,

Appellant, his wife Rose Hayes, and their four children were at the

home. The five adults began drinking and playing pool in the

basement for several hours. Rose was smoking marijuana, while

Zedekiah and Sims each consumed a pill that McKeda suspected

was Ecstasy. Sims, however, testified that the only drug he had in

3 his possession the night of the shooting was Percocet. Sims was also

under the influence of cocaine and Percocet the following day when

he was interviewed by investigators.

At 3:17 a.m. on January 17, Sims recorded and uploaded a

video to Instagram of the five adults socializing and playing pool in

the basement. At 4:09 a.m., Sims recorded and uploaded another

Instagram video, this time of Zedekiah, who also went by “Tenarus,”

asleep in the upstairs bathroom of the home. In the video Sims can

be heard saying, “We been looking for [Zedekiah] for the last thirty

minutes.” After finding Zedekiah, Sims and Appellant helped

Zedekiah into the upstairs bedroom, where Zedekiah joined

McKeda, who was already lying on the bed asleep. At some point,

Rose joined Zedekiah and McKeda on the bed. All three were fully

clothed.

At 4:34 a.m., Sims recorded and uploaded a final video to

Instagram showing Zedekiah, McKeda, and Rose on the bed, with

Zedekiah in the middle. Zedekiah and Rose can be heard on the

video talking aggressively to each other. Fifteen minutes after the

4 final video, Rose pushed Zedekiah to the ground, and in response,

McKeda attacked Rose, biting her over her eye.4 While Sims helped

Zedekiah off the ground, Appellant intervened to defend Rose

against McKeda. Seeing this, Zedekiah got involved in the

altercation and began to fight Appellant. Sims attempted to

separate the couples, but in the process of doing so, he heard

someone reference a gun and noticed Appellant was no longer in the

room. Sims also heard someone say, “[G]et these people out of my

house.”5 Upon hearing the reference to a gun and seeing Appellant

was no longer in the room, Sims immediately left the home.

After Sims left, the struggle between the couples continued.

McKeda, whose version of events leading up to and during the

struggle differed from Sims’s, testified that Rose was “fighting me

from behind and she’s biting me. She was taking her hands and

putting them in my eyes trying to hold me back and pulling my hair

4 McKeda and Rose were arrested and charged with multiple counts of

battery.

5 Sims testified that he was “not a hundred percent about who said what.” 5 and stuff.” While Rose attacked McKeda, McKeda attempted to

crawl over to Zedekiah, who was being punched in the eye by

Appellant. Eventually, Rose stopped attacking McKeda, and

McKeda crawled over to an unresponsive Zedekiah. As McKeda

urged Zedekiah to “[g]et up,” Appellant “[shot] Tenarus” once.

McKeda did not remember what type of gun Appellant used to shoot

Zedekiah because she claimed she did not “know guns.” However,

there was evidence that McKeda took a photo with a firearm, which

was unrelated to Zedekiah’s killing, on her lap prior to the day of the

shooting. There was no evidence presented to suggest that she

brought that firearm, or any other firearm, to Appellant’s home.

At 4:39 a.m., video footage from a camera above the garage of

a neighboring home on Willow Ridge Road, which is adjacent to

Viola Court, showed an individual walking away from the direction

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Abebe v. State
Supreme Court of Georgia, 2026
Julian R. Baughcum, Jr v. State
Court of Appeals of Georgia, 2026
Monroe v. State
Supreme Court of Georgia, 2026
Gravitt v. State
Supreme Court of Georgia, 2025
Jarrett Leopard v. State
Court of Appeals of Georgia, 2025
BOSTIC v. THE STATE (Two Cases)
Supreme Court of Georgia, 2025
Odies Christopher Wade v. State
Court of Appeals of Georgia, 2025
Hart v. State
Supreme Court of Georgia, 2025
Sims v. State
321 Ga. 627 (Supreme Court of Georgia, 2025)
Lecharles Jacoby Harrell v. State
Court of Appeals of Georgia, 2025

Cite This Page — Counsel Stack

Bluebook (online)
910 S.E.2d 198, 320 Ga. 505, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hayes-v-state-ga-2024.