Lynn v. State

852 S.E.2d 843, 310 Ga. 608
CourtSupreme Court of Georgia
DecidedDecember 21, 2020
DocketS20A1533
StatusPublished
Cited by21 cases

This text of 852 S.E.2d 843 (Lynn 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
Lynn v. State, 852 S.E.2d 843, 310 Ga. 608 (Ga. 2020).

Opinion

310 Ga. 608 FINAL COPY

S20A1533. LYNN v. THE STATE.

PETERSON, Justice.

James Morris Lynn, Jr., appeals his conviction for malice

murder and aggravated assault in connection with the beating death

of his wife, Tonya Lynn.1 Lynn argues that we should vacate the trial

1 The crimes occurred sometime between July 26 and July 27, 2011. In

October 2011, a Barrow County grand jury indicted Lynn for malice murder, felony murder predicated on aggravated assault, and aggravated assault. Lynn was convicted of malice murder following a jury trial in June 2012, but we reversed his conviction based on the erroneous exclusion of evidence. See Lynn v. State, 296 Ga. 109 (765 SE2d 322) (2014). Lynn was retried from August 26 to September 3, 2015, and the jury found him guilty on all counts. The trial court sentenced Lynn to life in prison without the possibility of parole for malice murder and to a 20-year concurrent term for aggravated assault; the felony murder count was vacated by operation of law. Lynn timely filed a skeletal motion for new trial, which the trial court denied on November 2, 2016. Substitute appellate counsel filed a motion for out-of-time appeal in March 2019, alleging that Lynn’s prior attorney failed to file a notice of appeal due to an oversight. The trial court granted the motion for out-of-time appeal, and Lynn filed an amended motion for new trial, raising claims that trial counsel was ineffective. See Maxwell v. State, 262 Ga. 541, 542-543 (3) (422 SE2d 543) (1992) (permitting a defendant to file a second motion for new trial following the grant of an out-of-time appeal, and giving the trial court the discretion to refuse to reopen issues decided in the first motion for new trial). On May 1, 2020, the trial court denied Lynn’s amended motion for new trial following a hearing. Lynn timely filed a notice of appeal. His case was docketed to this Court’s August 2020 term and submitted for a decision on the briefs. court’s order denying his motion for new trial for lack of adequate

findings and remand for more detailed findings. He also argues that

the trial court erred in denying his motion for a mistrial, he received

ineffective assistance of trial counsel, and the combined errors

cumulatively prejudiced him. But the trial court was not required to

make detailed findings in denying Lynn’s motion for new trial. The

trial court did not err in denying Lynn’s motion for a mistrial

because the alleged basis for a mistrial posed little prejudice to Lynn

and the court gave a sufficient curative instruction. Lynn’s

ineffective assistance claims fail because he has not established that

trial counsel performed deficiently in any respect. And his

cumulative error argument fails because there are no errors to

cumulate. We vacate Lynn’s sentence for aggravated assault

because this count should have merged with the malice murder

conviction, but we affirm the murder conviction.

The evidence at trial showed the following.2 After Tonya went

2 Because we consider the cumulative prejudice of alleged trial counsel

deficiencies, we present the evidence as jurors reasonably would have viewed it, rather than in the light most favorable to the jury’s verdict. 2 missing, police interviewed Lynn multiple times, and he eventually

admitted killing Tonya by hitting her in the head with a baseball

bat. He led police to a well where he had dumped her body. An

autopsy showed that Tonya died from blunt force trauma to the

head.

The State presented evidence showing that the couple had a

rocky relationship. Lynn and Tonya, who had four children together,

separated and both filed for a divorce in early 2011. During their

separation, Lynn and Tonya each started dating other people. Tonya

began a relationship with David Bulloch, while Lynn began a

relationship with Jennifer Butler. Lynn told Tonya’s aunt that he

was not going to share custody of his children with anyone.

The couple moved back in together in May 2011, but their

troubles continued. On May 13, 2011, Tonya was in her bedroom

watching a movie with one of her daughters and her niece. Tonya’s

niece testified that when Lynn arrived home from work, he began

an argument with Tonya about whether she was texting someone.

Lynn yelled at Tonya and flipped over the mattress Tonya was

3 sitting on, causing her to fall to the floor and injure her knee.

Tonya became increasingly scared of Lynn, telling people he

had said he would kill her before he let her go. One of Tonya’s

cousins explained that Tonya did not immediately leave Lynn

because Tonya was concerned about supporting herself and her

children on her salary, and Lynn controlled access to their bank

accounts. Tonya began taking steps to save money in order to leave

Lynn permanently.

Meanwhile, Lynn continued to communicate with Butler,

stating that he did not want to be a part-time dad and frequently

expressing his frustration with the pending divorce and fear that

Tonya would leave with their children. On June 30, Lynn wrote an

e-mail to Butler, saying, “I have high hopes my problem will soon be

gone for good. I have to be patient and bide my time wisely and

always have a good alibi[.]” In subsequent e-mails, Lynn expressed

his anger about the possibility of Tonya leaving with the children

and said that she “doesn’t deserve to even be living” and that he

thought he would be happy if she were “gone for good.”

4 On July 24, Tonya talked to Bulloch and told him that Lynn

threw her into a doorframe and that, as a result, she planned to

leave Lynn and take the children with her. The next day, Lynn

called Tonya’s cousin, Julie Royster Hollifield, saying that Tonya

wanted to leave him and asking Hollifield to convince Tonya to stay

with him. Hollifield and Tonya talked on July 26, and Tonya said

she had “decided for sure she was leaving” and had packed her

belongings.

The following day, July 27 Tonya failed to show up to work at

6:30 a.m. as scheduled. When Tonya was still absent at 7:30 a.m.,

her supervisor, Stacey Morris, began making phone calls in an

attempt to locate Tonya. Tonya’s co-workers called law enforcement,

and officers began searching for her. Tonya’s family members told

officers that Lynn claimed both that Tonya probably died due to a

heart condition and that one of Tonya’s cousins probably killed her.

Officers asked to interview Lynn and requested that he bring in his

cell phone because it might contain data that could help them in

their investigation. Lynn brought his cell phone, but it had been

5 “completely wiped” of all data.

Tonya’s SUV was found in a library parking lot on July 27, but

there were no signs of Tonya. Surveillance video from the library

showed that the vehicle was left there around 1:38 a.m. on July 27,

and that the male subject driving the SUV got into a truck that was

later determined to be owned by Butler. Police interviewed Butler,

who testified at trial that she went to the library to pick up Lynn

after he called her. After Butler’s interview, the police arrested Lynn

on obstruction charges because he had lied about not knowing how

Tonya’s vehicle came to be left at the library. During an interview

conducted after his arrest, Lynn admitted killing Tonya with a

baseball bat and told police where they could find her body.

Lynn testified in his defense at trial, claiming that he killed

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Bluebook (online)
852 S.E.2d 843, 310 Ga. 608, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lynn-v-state-ga-2020.