Hudson v. State

841 S.E.2d 696, 308 Ga. 443
CourtSupreme Court of Georgia
DecidedApril 6, 2020
DocketS20A0218
StatusPublished
Cited by12 cases

This text of 841 S.E.2d 696 (Hudson 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
Hudson v. State, 841 S.E.2d 696, 308 Ga. 443 (Ga. 2020).

Opinion

308 Ga. 443 FINAL COPY

S20A0218. HUDSON v. THE STATE.

PETERSON, Justice.

Phell Hudson, Jr., appeals his convictions for malice murder,

possession of a firearm during the commission of a felony, and

making a false statement, all stemming from the shooting death of

Michael Allen.1 Hudson argues that the trial court erred by failing

1 The crimes occurred on June 11, 2014. Hudson was indicted by a Chatham County grand jury on July 9, 2014, and charged with malice murder, felony murder (predicated on aggravated assault), aggravated assault, two counts of possession of a firearm during the commission of a felony, and making a false statement. A jury trial was held on December 14 to 15, 2015, and Hudson was found guilty of all counts. The trial court sentenced Hudson to life in prison for malice murder, five years concurrent for making a false statement, and five years for possession of a firearm during the commission of a felony to be served consecutive to the life sentence; the aggravated assault counts merged with malice murder, the remaining firearm count merged into the other, and the felony murder verdict was vacated by operation of law. On January 6, 2016, trial counsel timely filed a motion for new trial. On January 13, 2016, appellate counsel filed an additional motion for new trial, which was amended on June 6, 2016. Hudson filed a request to be forensically evaluated, and on July 22, 2016, the trial court entered an order directing the Georgia Department of Behavioral Health and Developmental Disabilities (DBHDD) to conduct a forensic evaluation of Hudson. On November 29, 2016, the DBHDD submitted a report under seal finding that Hudson was competent for the appeals process. Hudson sought an independent evaluation of his mental capacity to be criminally responsible; the independent evaluation was to instruct the jury on voluntary manslaughter and insanity at the

time of the alleged crimes. He also argues that the trial court erred

by limiting his cross-examination of a witness. His jury instruction

claims fail because the evidence presented at trial did not include

even slight evidence to support either charge. And his cross-

examination claim fails because any error was harmless. We affirm.

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

trial evidence showed the following. On June 11, 2014, around 2:00

p.m., Hudson, Allen, and several other friends were sitting in chairs

under a tree drinking beer on the outskirts of the parking lot of the

International Longshoreman’s Association (ILA), where they were

employed at the time. There was a discussion about obtaining more

beer. In that conversation, Allen said, referring to Hudson, “I’m

trying to get this mother f**ker to take me to the store.” Hudson,

conducted on May 18, 2017, concluding that Hudson was criminally responsible. A motion for new trial hearing was held on September 18, 2017. The court denied the motion in an order entered on August 10, 2018. Hudson filed a notice of appeal on September 6, 2018. This case was docketed to this Court’s term beginning in December 2019 and submitted for a decision on the briefs. instantly angered, responded “I’m not gone be a mother f**ker. You

know my mother just died.” Allen replied, “Man, leave your momma

out of this. You know we’re just kidding.”

Stephen Manes, a longtime co-worker of Allen and Hudson,

thought the exchange was done, as the conversation was typical for

when the men were drinking in the parking lot. A few minutes later,

Hudson walked to his car, where he sat talking to his brother on his

cell phone. Hudson got out, went to the trunk and “fumbled around”

for a short period, and got back in his car. Hudson then returned to

his trunk, grabbed a gun, and walked to Allen and the others,

holding his phone in his left hand and a semi-automatic revolver

with a red stripe on the handle in his right hand.

Upon reaching the group, Hudson was still on the phone,

telling his brother something like “if anything happens, you know

where my money is.” Hudson then told Allen he would kill him if he

did not leave in five minutes; Allen ignored Hudson. Hudson waited

five minutes, then kicked Allen out of his chair. At that point, Allen

jumped up and Hudson took a swing at him; Allen swung back. The two men fought for a few minutes, until two shots were fired and

Allen fell to the ground. The first shot missed Allen, but the next hit

him in the neck. Hudson said to Allen, “I told you I was gone kill

your mf***ing behind if you didn’t leave.” Hudson then got into his

car and drove away. Kevin Johnson, another longtime friend and co-

worker of Allen and Hudson, called 911; Allen died on the scene from

the gunshot wound. The entire incident ⸺ from the time Allen

insulted Hudson to the time of the shooting ⸺ took about thirty

minutes.

Eight minutes after the shooting was reported over police

radio, Sergeant Mike Arango spotted Hudson’s vehicle and pulled

him over. Sergeant Arango informed Hudson that he stopped him

because his vehicle matched the description of one that was just

involved in an incident at the ILA. Hudson denied being at the ILA

at all that day, claiming he had been at a friend’s house. A dispatch

alert came over Sergeant Arango’s radio that provided a description

of the suspect; the description matched Hudson “to a tee.” Sergeant

Arango asked Hudson if he had any weapons in the car; Hudson said that he did, but refused to consent to a search of his vehicle.

Sergeant Arango placed Hudson in the back of a patrol car. Hudson

was then transported to the police station where he spoke with

Detective Robert Santoro.

A search warrant was obtained for Hudson’s vehicle; a Taurus

.357 Magnum revolver with red marking on the handle was

recovered. The gun contained three live rounds and two spent .357

Magnum shell casings.

Manes testified at trial that he did not see Allen with a gun

that day. He also never saw Allen bullying or personally bothering

Hudson, and was not aware of ongoing issues between Hudson and

Allen. Johnson said in 20 years of knowing the men, he never saw

Allen bullying Hudson.

1. The evidence was sufficient to convict Hudson.

Hudson 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

was legally sufficient to authorize a rational trier of fact to find beyond a reasonable doubt that Hudson was guilty of the crimes for

which he was convicted. See Jackson v. Virginia, 443 U.S. 307, 319

(99 SCt 2781, 61 LE2d 560) (1979).

2. The trial court did not err by declining to give jury instructions on voluntary manslaughter and insanity.

Hudson argues that the trial court erred by refusing to instruct

the jury on voluntary manslaughter and insanity at the time of the

crimes. A request to charge must be “legal, apt, and precisely

adjusted to some principle involved in the case and be authorized by

the evidence.” Barron v. State, 297 Ga. 706, 708 (2) (777 SE2d 435)

(2015) (citation and punctuation omitted). “To authorize a

requested jury instruction, there need only be slight evidence

supporting the theory of the charge.” McClain v. State, 303 Ga. 6, 9

(2) (810 SE2d 77) (2018) (citation and punctuation omitted). It is a

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841 S.E.2d 696, 308 Ga. 443, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hudson-v-state-ga-2020.