Hyden v. State

839 S.E.2d 506, 308 Ga. 218
CourtSupreme Court of Georgia
DecidedFebruary 28, 2020
DocketS19A1496
StatusPublished
Cited by8 cases

This text of 839 S.E.2d 506 (Hyden 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
Hyden v. State, 839 S.E.2d 506, 308 Ga. 218 (Ga. 2020).

Opinion

308 Ga. 218 FINAL COPY

S19A1496. HYDEN v. THE STATE.

MELTON, Chief Justice.

Following a March 29 to 31, 2004 jury trial, Clark Milton

Hyden was found guilty of malice murder, felony murder,

kidnapping with bodily injury, and various other offenses in

connection with the beating death of Tommy Crabb, Sr.1 On appeal,

Hyden contends that the evidence presented at trial was insufficient

to support his kidnapping conviction under the standard set forth in

1 On February 10, 2003, Hyden was indicted for malice murder, felony

murder predicated on kidnapping with bodily injury, felony murder predicated on aggravated battery, kidnapping with bodily injury, aggravated battery, and aggravated assault. Following his March 2004 trial, Hyden was found guilty on all counts. He was sentenced to life in prison for malice murder and a consecutive life term for kidnapping with bodily injury. The aggravated battery and aggravated assault charges were merged into the malice murder count for sentencing purposes. The trial court also purported to merge the two felony murder counts into the malice murder count, but those counts were actually vacated by operation of law. See Malcolm v. State, 263 Ga. 369 (4) (434 SE2d 479) (1993). Hyden filed a motion for new trial on May 13, 2004, which he amended through new counsel on March 7, 2019. Following a March 8, 2019 hearing, the trial court denied the motion on April 26, 2019. Hyden filed a timely notice of appeal on May 6, 2019, and his appeal was docketed to the August 2019 term of this Court and submitted for a decision on the briefs. Garza v. State, 284 Ga. 696 (670 SE2d 73) (2008); that the trial court

erred by allowing the State to waive its initial closing argument;

that Hyden was denied his right to a speedy appeal; and that

Hyden’s trial counsel was ineffective. For the reasons that follow, we

affirm.

1. Although Hyden challenges the sufficiency of the evidence

only with regard to his kidnapping with bodily injury conviction, we

review the sufficiency of the evidence to support all of his

convictions, consistent with our customary practice in murder cases.

See, e.g., Walker v. State, 306 Ga. 579 (1) (832 SE2d 420) (2019).

When evaluating the sufficiency of evidence, “the relevant

question is whether, after viewing the evidence in the light most

favorable to the prosecution, any rational trier of fact could have

found the essential elements of the crime[s] beyond a reasonable

doubt.” (Citation and emphasis omitted.) Jackson v. Virginia, 443 U.

S. 307, 319 (III) (B) (99 SCt 2781, 61 LE2d 560) (1979). On appeal,

“this Court does not re-weigh the evidence or resolve conflicts in

testimony, but instead defers to the jury’s assessment of the weight

2 and credibility of the evidence.” (Citation omitted.) Curinton v.

State, 283 Ga. 226, 228 (657 SE2d 824) (2008).

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

presented at trial reveals that, on November 6, 2002, Crabb, an

electrician, went to Hyden’s home to teach Hyden how to fix a

kitchen light. Crabb knew Hyden because Hyden had helped Crabb

with odd jobs in the past. Crabb’s wife became worried when Crabb

did not come home for lunch that day as he normally would, and she

and her children began to drive around looking for him.

A family friend named Danny Fulcher and Fulcher’s

stepdaughter began looking for Crabb as well, and they went to

Hyden’s mobile home to see if Crabb might be there. Although

Fulcher and his stepdaughter had driven by the mobile home several

times on November 6 and seen lights on in the mobile home, Hyden’s

truck parked outside, and movement inside the mobile home, no one

answered when Fulcher and his stepdaughter stopped and knocked

on the door during the day. They returned to Hyden’s mobile home

around 1:00 a.m. and saw Hyden sitting on his front porch. They

3 spoke with Hyden, and he informed them that somebody had hit him

over the head when he and Crabb had been working on an electrical

outlet, and that he did not know where Crabb was because Hyden

had been unconscious since lunch time the previous day. Fulcher’s

stepdaughter called 911, but paramedics who responded did not find

evidence of any wound that they believed could have rendered

Hyden unconscious for 12 hours.

Later that morning, Crabb’s daughter and Fulcher’s

stepdaughter continued to search for Crabb, and they knocked on

the door of a mobile home behind Hyden’s. As they were leaving,

they saw Crabb’s truck, which was parked between Hyden’s mobile

home and the mobile home of one of his neighbors. Crabb’s daughter

went to the truck, where she discovered her father’s dead body,

covered by a spare tire, lying in the bed of the truck. Crabb’s

daughter called 911, and police arrived at the scene soon thereafter.

Hyden came out of his mobile home after police arrived at the scene

and said, “Oh damn there is [Crabb].”

Police went into Hyden’s mobile home and noticed the

4 unusually clean nature of Hyden’s kitchen in relation to the

remainder of his residence. Luminol spray revealed the presence of

blood on the kitchen floor. A forensic biologist later matched

swabbings taken from the floor with Crabb’s DNA. Police also found

a wadded-up paper towel with suspected blood on it and more

suspected blood between Hyden’s clothes dryer and the pantry wall,

as well as in an adjacent closet. In addition, police discovered a

bloody rubber mallet that had been discarded in a county dumpster,

and the blood from the mallet was later identified as matching

Crabb’s. In the area between Hyden’s house and Crabb’s truck

where Crabb’s body was found, police also found a cinder block with

Crabb’s blood on it. Crabb’s wallet and keychain were located behind

his pick-up truck, and luminol spray revealed a “drag trail” of blood

between Hyden’s home and the truck. Crabb had numerous blunt

force injuries to the top of his head, and the State’s medical examiner

testified that Crabb died from blunt force trauma consistent with

having been hit with a rubber mallet.

Hyden was arrested at the scene, and, after signing a waiver of

5 rights form, he was interviewed by police that same day. In his

interview, Hyden claimed that Crabb had come to his house to help

him with a broken light on the morning of November 6, and that a

man with a long black stick and a gun came in through Hyden’s back

door and knocked Hyden unconscious. Hyden claimed that, when he

woke up, Crabb and Crabb’s truck were gone. When questioned

about the presence of blood in his home, Hyden changed his story,

claiming that he saw the man with the stick beat Crabb, that blood

was everywhere, and that the man asked Hyden to help him clean

up. So Hyden retrieved a blanket and rags and cleaned up the scene,

and he placed Crabb on the blanket and dragged him across the

house. Hyden asserted that the man made him drag Crabb out of

the mobile home while Crabb was still alive and gasping for air.

Also, contrary to his original story in which he said he had been

knocked unconscious, Hyden said the man then handcuffed him to

the front door while he moved Crabb’s truck to the neighbor’s house.

Hyden claimed that he let the man leave the scene after the man

removed Hyden’s handcuffs, and that Hyden then drove around,

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

Related

GINES v. THE STATE (Three Cases)
Supreme Court of Georgia, 2026
Mikal Snow Mitchell v. State
Court of Appeals of Georgia, 2025
Jessie Strickland v. State
Court of Appeals of Georgia, 2024
Harper v. State
897 S.E.2d 818 (Supreme Court of Georgia, 2024)
Salvesen v. State
317 Ga. 314 (Supreme Court of Georgia, 2023)
Robert Lloyd Hicks v. State
Court of Appeals of Georgia, 2023
Caviston v. State
882 S.E.2d 221 (Supreme Court of Georgia, 2022)
Felts v. State
858 S.E.2d 708 (Supreme Court of Georgia, 2021)
FRETT v. STATE FARM EMPLOYEE WORKERS' COMPENSATION
844 S.E.2d 749 (Supreme Court of Georgia, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
839 S.E.2d 506, 308 Ga. 218, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hyden-v-state-ga-2020.