Mattei v. State

307 Ga. 300
CourtSupreme Court of Georgia
DecidedNovember 4, 2019
DocketS19A1332
StatusPublished
Cited by7 cases

This text of 307 Ga. 300 (Mattei 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
Mattei v. State, 307 Ga. 300 (Ga. 2019).

Opinion

307 Ga. 300 FINAL COPY

S19A1332. MATTEI v. THE STATE.

MELTON, Chief Justice.

Following a jury trial, Paul Joseph Mattei was found guilty of

malice murder, aggravated assault, and various other offenses in

connection with the shooting death of Angela Williams.1 On appeal,

Mattei contends that the evidence presented at trial was insufficient

to support his convictions and that the trial court erred by admitting

1 On December 9, 2011, a Fulton County grand jury indicted Mattei for

malice murder, felony murder predicated on aggravated assault, felony murder predicated on armed robbery, felony murder predicated on possession of a firearm by a convicted felon, armed robbery, aggravated assault with a deadly weapon, possession of a firearm during the commission of a felony, possession of a firearm by a convicted felon, and insurance fraud. Following a jury trial ending on March 4, 2014, the jury found Mattei guilty on all counts except for felony murder predicated on armed robbery and armed robbery. The trial court sentenced Mattei as a recidivist to life without parole for malice murder, two consecutive five-year terms for the weapons charges, and a consecutive ten- year term for insurance fraud, for a total of life plus twenty years. The two felony murder counts were vacated by operation of law, see Malcolm v. State, 263 Ga. 369 (4) (434 SE2d 479) (1993), and the aggravated assault count merged into the malice murder count for sentencing purposes. Mattei filed a motion for new trial on March 7, 2014, which he subsequently amended through new counsel on January 26, 2018. On April 10, 2018, after a hearing, the trial court denied Mattei’s motion. Mattei timely filed a notice of appeal to this Court. His appeal was docketed to the August 2019 term of this Court and submitted for a decision on the briefs. at trial character evidence in violation of OCGA § 24-4-404 (b). For

the reasons set forth below, we affirm.

1. Viewed in the light most favorable to the verdicts, the

evidence shows that, on the evening of June 30, 2011, Mattei shot

Angela Williams twice in the chest and once in the arm, while

Williams sat in her car in an isolated parking lot in Fairburn.

Mattei then left the scene in his yellow truck, and Williams managed

to drive herself a little over one half of a mile to a gas station, where

police found her barely conscious. Despite being rushed to the

hospital, she was pronounced dead upon arrival. The Fulton County

medical examiner concluded that Williams’s death was caused by a

gunshot wound to the chest.

Two months prior to the murder, Williams and Mattei had

entered into a “marriage of convenience.” The two did not move in

together and kept their marriage largely a secret. Williams told a

family member that the purpose of the marriage was for her to assist

Mattei with a drug trafficking scheme involving a trip to the

Bahamas. The same day that they married, Mattei added Williams

2 as his spouse to his insurance policy. Under the terms of Mattei’s

family-rider policy, Mattei would collect $150,000 upon his spouse’s

accidental death.

Days before the Bahamas trip, Mattei told Williams the plan

had changed, and they would be going to Florida instead of the

Bahamas. On the night of her murder, Williams was scheduled to

meet with Mattei to discuss their travel plans. Video surveillance

recordings from surrounding businesses showed Williams’s vehicle

following Mattei’s truck in the direction of the parking lot where she

was shot, just ten minutes before the shooting. The recordings also

showed his truck driving away from the scene shortly before rescue

vehicles arrived.

Police discovered that searches for how to obtain a death

certificate had been made on Mattei’s computer hours after

Williams’s shooting. The police also discovered that Mattei had

made three inquiries between June 18, 2011 and July 4, 2011,

checking on his life insurance policy. In a search of Mattei’s vehicle

after his arrest, police found paperwork that could be used to file a

3 life insurance claim along with information on how to obtain a death

certificate. On August 12, 2011, after obtaining the death certificate

from Williams’s daughter, Mattei notified the insurance company of

Williams’s death.

At trial, Crystal Bridges, Mattei’s former roommate, testified

that shortly after she moved in with Mattei in December 2009, he

approached her about an insurance fraud scheme involving him

running her over with his truck so they could file an insurance claim.

A jailhouse informant, Marlon Avila, testified that in July 2013, he

and Mattei were housed in the same unit. During that time, Mattei

told Avila that he had shot his wife three times with a .380 handgun.

An analysis of the shell casings recovered from Williams’s car

showed she had been shot with a .380 handgun.

Mattei attacks Avila’s testimony regarding his confession as

“uncorroborated and unreliable.” But, issues of witness credibility

are for the jury to decide. See Hayes v. State, 292 Ga. 506, 506 (739

SE2d 313) (2013). Based on the foregoing, we conclude that the

evidence was sufficient to enable a rational trier of fact to conclude

4 beyond a reasonable doubt that Mattei was guilty of the crimes for

which he was convicted. See Jackson v. Virginia, 443 U. S. 307, 319

(III) (B) (99 SCt 2781, 61 LE2d 560) (1979).

2. Next, Mattei contends that the trial court erred by admitting

into evidence Bridges’s testimony about Mattei’s 2009 conversation

with her regarding a proposed insurance scheme. According to

Mattei, this conversation was extrinsic evidence that had no logical

relation or relevance to the charged murders. We disagree.

Because Mattei’s trial occurred after January 1, 2013, the

admissibility of the extrinsic evidence in question in this case is

governed by OCGA § 24-4-404 (b) (“Rule 404 (b)”). See Booth v.

State, 301 Ga. 678 (3) (804 SE2d 104) (2017). And, a trial court’s

decision regarding the admissibility of such evidence is reviewed for

abuse of discretion. See Smith v. State, 302 Ga. 717 (4) (808 SE2d

661) (2017). Rule 404 (b) provides in relevant part:

Evidence of other crimes, wrongs, or acts shall not be admissible to prove the character of a person in order to show action in conformity therewith. It may, however, be admissible for other purposes, including, but not limited to, proof of motive, opportunity, intent, preparation, plan,

5 knowledge, identity, or absence of mistake or accident.

Other acts evidence is admissible where:

(1) the evidence is relevant to an issue in the case other than the defendant’s character, (2) the probative value is not substantially outweighed by undue prejudice, and (3) there is sufficient proof for a jury to find by a preponderance of the evidence that the defendant committed the prior act.

Brannon v. State, 298 Ga. 601, 606 (4) (783 SE2d 642) (2016).2

Here, the trial court found that Bridges’s testimony was

admissible for the proper purpose of showing motive. “Motive is the

reason that nudges the will and prods the mind to indulge the

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

Related

Momon v. State
Supreme Court of Georgia, 2025
Jimmy Collum v. State
Court of Appeals of Georgia, 2025
Wilson v. State
Supreme Court of Georgia, 2025
Harris v. State
Supreme Court of Georgia, 2025
Thomas v. State
853 S.E.2d 111 (Supreme Court of Georgia, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
307 Ga. 300, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mattei-v-state-ga-2019.