Madera v. State

899 S.E.2d 132, 318 Ga. 593
CourtSupreme Court of Georgia
DecidedMarch 5, 2024
DocketS24A0148
StatusPublished
Cited by3 cases

This text of 899 S.E.2d 132 (Madera 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
Madera v. State, 899 S.E.2d 132, 318 Ga. 593 (Ga. 2024).

Opinion

318 Ga. 593 FINAL COPY

S24A0148. MADERA v. THE STATE.

BETHEL, Justice.

Francisco Javier Madera was convicted of the malice murder of

Juan Carlos Zambrano.1 On appeal, Madera raises five claims of

error: (1) the trial court erred by denying his motion for new trial on

the general grounds; (2) the trial court erred by admitting video

footage of the injured Zambrano; (3) the trial court erred by

admitting evidence pursuant to OCGA § 24-8-803 (5); (4) trial

counsel was ineffective in two respects; and (5) the cumulative effect

of the trial court’s errors and counsel’s deficient performance

1 The crimes occurred on October 13, 2017. In January 2018, a Cobb

County grand jury indicted Madera for malice murder, felony murder, and aggravated assault. Following a September 2019 jury trial, Madera was found guilty of all counts. The trial court sentenced Madera to serve life in prison for malice murder; the felony murder count was vacated by operation of law, and the aggravated assault count merged for sentencing. Madera filed a timely motion for new trial, which he amended through new counsel. Following a hearing, the trial court denied the motion, as amended, on August 2, 2023. Madera thereafter filed a timely notice of appeal, and the case was docketed to this Court’s term commencing in December 2023 and submitted for a decision on the briefs. requires a new trial. For the reasons that follow, we affirm.

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

evidence presented at trial showed as follows. On the night of

October 13, 2017, Madera, Zambrano, and others attended a party

at the Cobb County home of Elma Escobar. While Madera and

Zambrano were dancing with the same woman, the two began

arguing, and, later in the evening, they physically fought each other.

Several partygoers separated Madera and Zambrano, and Escobar

asked Madera to leave.

Escobar walked Madera to his vehicle, and Madera began to

leave. As Escobar was walking back to the house, however, she

heard Madera “unlocking” his firearm and saw that he had stopped

his vehicle in the road and had exited the vehicle. Though Escobar

grabbed Madera and tried to calm him, he pointed his gun at

Zambrano and fired. Witnesses testified that, immediately before

the shooting, Zambrano was hugging another partygoer, and three

witnesses testified that Zambrano did not have anything in his

hands when he was shot and did not have a gun in his possession

2 that night. Escobar heard one gunshot followed by two more and

then saw Zambrano clutching his abdomen. Zambrano fell to the

ground after being shot. Edwin Santos Saez, another partygoer,

testified that, after Zambrano fell to the ground, Madera shot him

again. Another partygoer heard Madera direct two slurs at

Zambrano during the shooting. After shooting Zambrano, Madera

fled and was arrested two days later at a hotel in Little Rock,

Arkansas.

Escobar called an ambulance and the police, but Zambrano

asked to be driven to the hospital. Zambrano was placed in Saez’s

vehicle, and en route to the hospital, Saez crossed paths with and

flagged down officers responding to Escobar’s earlier call. Officers

found the unconscious Zambrano in the front passenger seat; he had

gunshot wounds to the left side of his abdomen and the upper area

of his back. The officers applied pressure to Zambrano’s wounds

while waiting for emergency medical services to arrive, and their

actions were captured by their body cameras. Zambrano was

transported to the hospital, where he died as a result of his wounds

3 the following day.

At trial, Madera testified that he acted in self-defense after

seeing a snub-nosed revolver in Zambrano’s right hand. The State,

however, presented evidence showing that no weapons were found

on Zambrano’s person or during a search of Saez’s vehicle and that

no guns or ammunition were found during a search of Escobar’s

home the day after the shooting.

On appeal, Madera first argues that the trial court should have

granted him a new trial on the “general grounds” because, he says,

some of the evidence against him was conflicting. See OCGA §§ 5-5-

20 (authorizing grant of new trial if the trial judge concludes that

the jury’s verdict is “contrary to evidence and the principles of justice

and equity”) and 5-5-21 (authorizing grant of new trial if the trial

judge concludes that the jury’s verdict is “decidedly and strongly

against the weight of the evidence”). The general grounds require a

trial court “to exercise a broad discretion to sit as a ‘thirteenth juror’”

and “consider some of the things that he cannot when assessing the

legal sufficiency of the evidence, including any conflicts in the

4 evidence, the credibility of witnesses, and the weight of the

evidence.” Hinton v. State, 312 Ga. 258, 262 (1) (c) (862 SE2d 320)

(2021) (citation and punctuation omitted). “We review whether the

trial court exercised its discretion as the thirteenth juror, but the

decision to grant a new trial on the general grounds is vested solely

in the trial court and not subject to our review.” Weems v. State, 318

Ga. 98, 102-103 (3) (897 SE2d 368) (2024). Here, in its order denying

Madera’s motion for new trial, the trial court, after stating that it

independently reviewed the evidence and considered the credibility

of witnesses, expressly rejected Madera’s general grounds claim.

Thus, the trial court’s order shows that the court properly exercised

its discretion under OCGA §§ 5-5-20 and 5-5-21, and Madera’s

argument “is otherwise not subject to review by this Court.”2 See

2 Madera does not separately argue that the evidence was insufficient to

support his conviction as a matter of constitutional due process under Jackson v. Virginia, 443 U. S. 307 (99 SCt 2781, 61 LE2d 560) (1979). In previous appeals in which an appellant raised a general-grounds claim, we have often reviewed the sufficiency of the evidence as a matter of constitutional due process, though many of us have questioned the soundness of that approach. See King v. State, 316 Ga. 611, 616 (2) n.8 (889 SE2d 851) (2023). Like in King, however, we need not determine the propriety of that approach in this case because the evidence against Madera was constitutionally sufficient to affirm his conviction. 5 Weems, 318 Ga. at 103 (3).

2. Madera next challenges the admission of a video and audio

recording from a police officer’s body camera which showed

emergency responders rendering aid to the wounded Zambrano in

Saez’s vehicle. Specifically, Madera asserts for the first time on

appeal that the admission of an “excessive number of photographic

exhibits” at trial, including autopsy photographs, rendered the body

camera footage cumulative and, thus, “unfairly prejudicial.”

Because Madera did not object on this basis at trial, we review this

claim only for plain error.3 See Gates v. State, 298 Ga. 324, 327 (3)

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