King v. State

889 S.E.2d 851, 316 Ga. 611
CourtSupreme Court of Georgia
DecidedJune 21, 2023
DocketS23A0214
StatusPublished
Cited by27 cases

This text of 889 S.E.2d 851 (King 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
King v. State, 889 S.E.2d 851, 316 Ga. 611 (Ga. 2023).

Opinion

316 Ga. 611 FINAL COPY

S23A0214. KING v. THE STATE.

WARREN, Justice.

After a jury trial in January 2020, Rico Jabar King was

convicted of the malice murder of Michael Brooks and possession of

a firearm during the commission of a felony based on shooting

Brooks.1 King raises four claims of error on appeal: (1) that the trial

court erroneously denied King’s motion for a new trial on the

“general grounds”; (2) that the trial court should not have allowed

witness testimony and closing arguments about voluntary

1 The crimes occurred on March 28, 2018. On May 24, 2018, a DeKalb County grand jury indicted King on four counts: malice murder, felony murder, aggravated assault, and possession of a firearm during commission of a felony. After a jury trial from January 14 to 23, 2020, King was found guilty on all counts. On January 23, 2020, King was sentenced to life in prison without the possibility of parole for malice murder and five years to be served consecutively for possession of a firearm during the commission of a felony. The remaining counts either were vacated by operation of law or merged with other counts. King filed a timely motion for new trial on February 18, 2020, which he amended on April 13, 2022. On June 22, 2022, the trial court denied King’s amended motion for new trial. King timely filed a notice of appeal on July 19, 2022, directed to the Court of Appeals, which was transferred to this Court on October 5, 2022. The case was docketed in this Court to the term beginning in December 2022 and submitted for a decision on the briefs. intoxication; (3) that the trial court plainly erred by admitting

character evidence about King’s alleged past alcohol and illegal drug

use; and (4) that King received constitutionally ineffective

assistance of counsel.

As explained more below, we conclude that King’s general

grounds claim fails. The trial court did not plainly err by allowing

witness testimony about voluntary intoxication, and King waived

his claim that the trial court should not have allowed closing

arguments about voluntary intoxication. King also affirmatively

waived his claim that the trial court erred by admitting purported

character evidence about King’s past alcohol and illegal drug use.

And King has failed to show that he received constitutionally

ineffective assistance of counsel. We therefore affirm King’s

convictions.

1. (a) The evidence presented at trial showed the following.

On March 28, 2018, just before noon, Brooks was walking down the

sidewalk on Glenwood Road in DeKalb County. King was in his

black pickup truck driving down Glenwood Road in the same

2 direction. Shortly after passing Brooks, King pulled into the parking

lot of a restaurant and parked his truck parallel to the road. Once

Brooks walked past King’s passenger-side window, King fired a shot

at Brooks with a .40-caliber pistol.

A witness who worked at a shopping center on the corner of

Glenwood Road heard the gunshot. He looked out the window and

“saw a guy fall down right beside the pickup truck that was over at”

a restaurant. He then saw Brooks2 “pushing himself down the

sidewalk” before King stepped out of the pickup truck with a gun.

Brooks stood up.

That witness and three other witnesses saw Brooks try to make

his way across Glenwood Road before he was shot again, causing

him to fall down in the street. One of the witnesses testified that

the shooter, whom she identified at trial as King, then “stood over

[Brooks], and emptied his whole clip.” Two of the witnesses watched

the shooting from inside a shop on Glenwood Road and testified that

2 None of the eyewitnesses knew Brooks or King, and only one identified

King at trial. 3 they were beating on a window as they watched; once King was done

shooting, he looked at them, nodded his head, and walked away.

After the shooting, King walked back to his pickup truck

without a sense of urgency and drove off. None of the witnesses had

heard or seen any other interaction between King and Brooks before

the shooting.

Multiple people called 911 to report the shooting and police

quickly responded. Shortly thereafter, three police officers spotted

King’s pickup truck driving down the road. The officers attempted

to stop the pickup truck, but King continued to drive at around 30

to 40 miles per hour, without obeying traffic lights or stop signs, for

a few miles before pulling into a gated apartment complex. King

attempted to enter the gate code. Although King at first did not

respond to police commands to exit the truck, the officers eventually

were able to remove him from the truck and take him into custody.

Back at the crime scene, Brooks’s body was found in the middle

of the road. He had been shot 13 times and died as the result of the

gunshot wounds. The medical examiner later determined that the

4 manner of death was homicide, and the parties later stipulated that

the gun used to shoot Brooks was a .40-caliber handgun recovered

from King’s pickup truck.

(b) Later on the day of the crimes, Detective Keith McQuilkin

interviewed King at DeKalb County police headquarters. Detective

McQuilkin read King his rights under Miranda,3 which King

waived. A recording of this interview was played for the jury. In

the interview, King stated that the police stopped him because he

“shot someone.” King said that he shot Brooks with his .40-caliber

Smith & Wesson handgun, which he left in his pickup truck. When

Detective McQuilkin asked what happened, King said he “really just

shot him” and that he “murdered him.” Among other things, King,

in explaining why he shot Brooks, said, “I guess I had to kill the

baby”;4 that he thought Brooks was the devil; and that he thought

Brooks was going to kill him, but Brooks did not say anything to

3 Miranda v. Arizona, 384 U.S. 436 (86 SCt 1602, 16 LE2d 694) (1966).

4 As explained in Division 1 (c), a psychiatrist testified at trial that, in

his opinion, King thought that Brooks was a “baby” version of King. King was 42 years old and Brooks was 29 when the crimes occurred.

5 make King think that. King also went back and forth between

saying that he did and did not know Brooks.5

King was charged with malice murder, felony murder,

aggravated assault, and possession of a firearm during commission

of a felony in connection with Brooks’s killing.

(c) King asserted insanity as a defense at trial, arguing that he

lacked the ability to distinguish between right and wrong during the

commission of the crimes. King called multiple witnesses at trial to

support that defense.

Three of those witnesses provided expert testimony. The first

was Dr. Matthew Norman, a licensed psychiatrist, whom the trial

court qualified as an expert in psychiatry, forensic psychiatry, and

psychiatric pharmacology. He testified that there was “clear

evidence that [King] was psychotic” on the day of the crimes, and

that someone experiencing King’s symptoms would have had

5 Detective McQuilkin ultimately determined that King and Brooks did not know each other. 6 “difficulty” distinguishing between right and wrong on the day of the

shooting.

In Dr. Norman’s opinion, King’s “thinking at the time of the

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889 S.E.2d 851, 316 Ga. 611, Counsel Stack Legal Research, https://law.counselstack.com/opinion/king-v-state-ga-2023.