London v. State

549 S.E.2d 394, 274 Ga. 91, 2001 Fulton County D. Rep. 2237, 2001 Ga. LEXIS 585
CourtSupreme Court of Georgia
DecidedJuly 16, 2001
DocketS01A0404
StatusPublished
Cited by30 cases

This text of 549 S.E.2d 394 (London 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
London v. State, 549 S.E.2d 394, 274 Ga. 91, 2001 Fulton County D. Rep. 2237, 2001 Ga. LEXIS 585 (Ga. 2001).

Opinions

Hunstein, Justice.

Keith London was convicted of malice murder, two counts of felony murder, and cruelty to children arising out of the death of two-year-old Briana Cansler. He appeals from the denial of his amended motion for new trial.1 Finding no reversible error, we affirm.

1. The evidence adduced at trial authorized the jury to find that the victim and her three-year-old sister, Brittany Cansler, were at home with appellant, their mother’s boyfriend, when he began abusing the victim. Brittany observed appellant hit the victim and throw her down the staircase. Afterwards, appellant called Brittany’s mother and asked that she return home from work because her daughter had been injured. When she arrived at the house the mother found appellant sitting on the couch holding the victim. The victim was gasping for air and her head was swollen. The victim died from blunt head trauma. Brittany, the only eyewitness to the attack, revealed to her mother while she was sitting in the emergency waiting room that appellant had hit the victim and knocked her down the stairs. Appellant denied harming the child and reported to police that she had fallen down the stairs. However, extensive trial testimony from medical personnel established that the victim had been abused prior to the fall and that the fall itself could cause injuries of such magnitude only if the victim had been thrown down the stairs. The numerous doctors who examined the child, including the medical examiner, testified that the victim suffered from shaken infant syndrome and battered child syndrome. She had multiple bruises over much of her body, including her arms, left side, chest, head, ears, and [92]*92anus. The doctors testified that from the circular bruises on her arms, it appeared as if someone had grabbed her very hard; the bruising around her anus was consistent with a direct trauma blow, such as a hard kick with a pointed shoe or having a broom stick pushed into the rectum. The victim also suffered a skull fracture on the back of her head, bruising to her brain indicating that she had been struck by something, and hemorrhaging around the thyroid gland. Blood behind her eyes revealed that the victim had been shaken back and forth and the severe bruising of her ears indicated that someone had flung her around while pinching her ears. The jury was also authorized to conclude that this was not the first time the victim had been left in appellant’s care and suffered a serious injury. The State adduced evidence which showed that six months earlier, in May 1995, the victim was hospitalized for a head injury which appellant claimed she suffered when she fell off the top Of a bunk bed and then had three bicycles fall on top of her. Again, although the child suffered severe injuries, appellant failed to call for emergency assistance. The evidence also demonstrated that appellant’s claim of how the injury occurred was deemed by medical professionals to be wholly inconsistent with the gravity and extent of the injuries received. The medical testimony regarding this prior incident also showed that the previous injury was consistent with child abuse. Likewise, medical testimony established that two weeks before her death the victim suffered a fracture to her arm which had been left untreated. Appellant contends the evidence was insufficient to support the convictions because the evidence was entirely circumstantial. “To warrant a conviction on circumstantial evidence, the proved facts shall. . . exclude every other reasonable hypothesis save that of the guilt of the accused.” OCGA § 24-4-6. Questions as to the reasonableness of hypotheses are generally to be decided by the jury which heard the evidence. Where the jury is authorized to find that the evidence, though circumstantial, was sufficient to exclude every reasonable hypothesis save that of guilt, that finding will not be disturbed unless the verdict of guilty is insupportable as a matter of law. Robbins v. State, 269 Ga. 500 (1) (499 SE2d 323) (1998). We conclude that the evidence was sufficient to authorize a rational trier of fact to find appellant guilty of the crimes charged beyond a reasonable doubt. Jackson v. Virginia, 443 U. S. 307 (99 SC 2781, 61 LE2d 560) (1979).

2. In his second enumeration of error, appellant contends that the trial court erred in denying the motion for mistrial that he made after the admission of certain testimony from Julie Dunton, a state’s witness. We conclude, however, that the trial court did not abuse its discretion in determining that a curative instruction was adequate to preserve appellant’s right to a fair trial, and that the grant of a mistrial was not essential in order to preserve that right. See Scruggs v. [93]*93State, 273 Ga. 752 (545 SE2d 888) (2001).

3. Appellant also contends that the trial court erred in admitting the testimony of Brittany Cansler, who was four years old at the time of trial. More specifically, appellant contends that, because of her age and immaturity, Brittany did not have sufficient reasoning power to answer questions intelligently. At trial, however, appellant challenged Brittany’s competency on the ground that she was incompetent as a matter of law because of her infancy. Although a child is subject to a competency challenge on the ground that she does not have the use of reason, see OCGA §§ 24-9-5, 24-9-7; Norton v. State, 263 Ga. 448, 449-450 (3) (435 SE2d 30) (1993); Sizemore v. State, 262 Ga. 214 (416 SE2d 500) (1992), a child is not incompetent as a matter of law because of her infancy. Accordingly, we conclude that the trial court did not err in denying appellant’s motion to prohibit Brittany from testifying on the ground of her infancy.

4. Appellant contends that the trial court erred by admitting hearsay statements made by Brittany that appellant had abused the victim and then thrown her down the stairs. The trial court admitted Brittany’s hearsay statements under OCGA § 24-3-16, the child hearsay statute. After appellant’s trial, we held in Woodard v. State, 269 Ga. 317, 321-323 (496 SE2d 896) (1998), that the child hearsay statute was unconstitutional to the extent it permitted the introduction into evidence of hearsay statements made by a child under the age of 14 describing physical or sexual abuse inflicted on another person. Thereafter, in denying appellant’s amended motion for new trial, the trial court ruled that Brittany’s statements were nevertheless admissible as prior inconsistent statements under the rationale of Gibbons v. State, 248 Ga. 858 (286 SE2d 717) (1982).

(a) Appellant’s contention that the hearsay statements were not admissible as prior inconsistent statements because Brittany was not available for cross-examination, is without merit inasmuch as our review of the record shows that Brittany answered numerous questions regarding herself, her family, her home, and her pet, and answered several general questions about the crime, testifying, for example, that she, appellant, and the victim were upstairs when the victim died. As for more specific questions regarding the crime, Brittany answered many times that she did not see anything happen or evaded answering the questions.

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

Related

Brookins v. State
879 S.E.2d 466 (Supreme Court of Georgia, 2022)
Puckett v. State
303 Ga. 719 (Supreme Court of Georgia, 2018)
Greene v. State
303 Ga. 184 (Supreme Court of Georgia, 2018)
Marchman v. State
787 S.E.2d 734 (Supreme Court of Georgia, 2016)
Mosley v. State
785 S.E.2d 297 (Supreme Court of Georgia, 2016)
Smith v. State
783 S.E.2d 91 (Supreme Court of Georgia, 2016)
Rutledge v. State
779 S.E.2d 275 (Supreme Court of Georgia, 2015)
Warren Hampton Pennington v. State
Court of Appeals of Georgia, 2013
Pennington v. State
746 S.E.2d 768 (Court of Appeals of Georgia, 2013)
Moore v. State
712 S.E.2d 126 (Court of Appeals of Georgia, 2011)
Bryant v. State
708 S.E.2d 362 (Supreme Court of Georgia, 2011)
Smith v. State
667 S.E.2d 421 (Court of Appeals of Georgia, 2008)
Revells v. State
640 S.E.2d 587 (Court of Appeals of Georgia, 2006)
Phillips v. State
629 S.E.2d 130 (Court of Appeals of Georgia, 2006)
Kennedy v. State
592 S.E.2d 830 (Supreme Court of Georgia, 2004)
Hanson v. State
587 S.E.2d 200 (Court of Appeals of Georgia, 2003)
Vaska v. State
74 P.3d 225 (Court of Appeals of Alaska, 2003)
Lloyd v. State
577 S.E.2d 854 (Court of Appeals of Georgia, 2003)
Jellie v. State
573 S.E.2d 490 (Court of Appeals of Georgia, 2002)
Head v. State
569 S.E.2d 548 (Court of Appeals of Georgia, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
549 S.E.2d 394, 274 Ga. 91, 2001 Fulton County D. Rep. 2237, 2001 Ga. LEXIS 585, Counsel Stack Legal Research, https://law.counselstack.com/opinion/london-v-state-ga-2001.