Ramirez v. State

897 S.E.2d 422, 318 Ga. 53
CourtSupreme Court of Georgia
DecidedJanuary 17, 2024
DocketS23A0905
StatusPublished

This text of 897 S.E.2d 422 (Ramirez 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
Ramirez v. State, 897 S.E.2d 422, 318 Ga. 53 (Ga. 2024).

Opinion

318 Ga. 53 FINAL COPY

S23A0905. RAMIREZ v. THE STATE.

PINSON, Justice.

Appellant Amalia Ramirez was convicted of the malice murder

of her elderly mother, Himilce Ramirez, after Himilce was found

dead in Ramirez’s home in a barren room. Ramirez was Himilce’s

sole caregiver, and Himilce was found with signs of severe neglect,

including sepsis, necrosis, stage-four bedsores, and parts of her body

fused together from lack of movement.1 Ramirez argues on appeal

1 Himilce died on December 6, 2018. On November 19, 2019, a Forsyth

County grand jury returned an indictment charging Ramirez with malice mur- der (Count 1), felony murder predicated on exploitation of an elder person (Count 2), felony murder predicated on neglect of an elder person (Count 3), exploitation of an elder person (Count 4), and neglect of an elder person (Count 5). After a jury trial from June 28, 2021, to July 13, 2021 (which included a recess from July 2, 2021, until July 12, 2021), the jury found Ramirez guilty of all counts. On July 13, 2021, the trial court sentenced Ramirez to life in prison for the malice murder (Count 1) and the remaining counts either merged or were vacated by operation of law. On the same day, Ramirez, through trial counsel, filed a timely motion for new trial, which was later amended by new counsel on June 29, 2022. After a hearing, the trial court denied the motion for new trial, as amended, on March 1, 2023. Ramirez filed a timely notice of ap- peal on March 6, 2023. Her appeal was docketed to the August 2023 term of this Court and submitted for a decision on the briefs. that her conviction was not supported by sufficient evidence because

there was no evidence of malice. But the evidence, which we recount

in detail below, was sufficient to authorize the jury to find that

Ramirez acted with malice. So we affirm her conviction.

1. Viewed in the light most favorable to the verdict, the evi-

dence showed that Himilce, who was 83 years old, died of a combi-

nation of sepsis, stage-four pressure ulcers (i.e., bedsores) with oste-

omyelitis (inflammation of the bone), dehydration, and mild bron-

chopneumonia. Ramirez did not report Himilce’s death. Instead, law

enforcement arrived at the home where Ramirez and Himilce lived

in response to a suicide threat by Ramirez, who reported that she

had nothing to live for and had taken pills to kill herself because her

mother was dead. After entering the house, the responding patrol

officer noticed a foul smell. At the officer’s request, Ramirez led him

to the room where Himilce’s body lay. Paramedics and investigators

arrived soon after and confirmed Himilce’s death.

Ramirez said that she had last seen Himilce alive around 9:00

or 10:00 the night before the officers arrived. Ramirez said that she

2 then woke up around 3:30 a.m., checked on Himilce, and discovered

she was dead. At that time, Ramirez washed Himilce’s body with

soap and water and changed her diaper and T-shirt.

Ramirez told police she had quit her job two years before to

care for Himilce full-time. She said she made meals for Himilce and

changed her clothes and diaper; she said Himilce would sometimes

complain if her diaper had not been changed. Ramirez also said that

Himilce was bedridden and sometimes made noises indicating pain,

but Ramirez did not know what type of pain Himilce was experienc-

ing, did not think Himilce had any medical diagnoses, and did not

take Himilce to the doctor or give her any medication. A neighbor

who had lived across the street from Ramirez for between one-and-

a-half and two years had never met or seen Himilce.

Overall, Ramirez’s home appeared clean and was filled with

scented candles. But the room where Himilce’s body was found was

dirty, with cat litter on the carpet and cobwebs in the ceiling corners,

and it smelled like urine, feces, and body odor. The room had no fur-

niture or décor other than a bare mattress on a box spring, a chair

3 “full of stuff” including an “unidentified mess,” and a television. The

mattress and box spring were covered in plastic, holes were worn

into the plastic, and where the mattress and box spring were ex-

posed, they were stained brown. Himilce was covered with a blanket

and dressed in a T-shirt and an unsecured adult diaper.

Detective Lauren Belfani, the lead investigator, described the

crime scene as “shocking” and “heartbreaking.” When investigators

removed the blanket from Himilce’s body to photograph her, Detec-

tive Belfani immediately observed that Himilce’s feet and lower legs

looked like “scales” or “leather.” Detective Belfani also observed that

Himilce’s arms appeared to be different sizes and saw sores on

Himilce’s legs, under her diaper, and on her back. Detective Belfani

said that some of the sores on Himilce’s back smelled and looked to

be black in color. The photos the investigators took of Himilce’s body

were admitted into evidence and published to the jury.

Both parties presented expert testimony about Himilce’s med-

ical condition. Both experts agreed the cause of Himilce’s death was

a combination of sepsis, bedsores with osteomyelitis, dehydration,

4 and bronchopneumonia. Photos from Himilce’s autopsy were admit-

ted into evidence and published to the jury.

The medical examiner explained that sepsis is an infection that

starts in one organ and spreads throughout the body via the blood-

stream. It is treatable with antibiotics. The medical examiner con-

cluded that Himilce’s sepsis likely originated with a urinary tract

infection, but the medical examiner could not rule out an association

between the sepsis and an infection to the bone from Himilce’s stage-

four bedsores. The medical examiner explained that symptoms of

sepsis typically include fever and sometimes vomiting. The level of

infection in Himilce’s body was at a “panic level,” which would have

required immediate attention before she died.

The medical examiner explained that a bedsore is “a lesion on

the skin that forms from pressure of the skin onto a surface from not

moving very much.” Bedsores begin as redness or irritation of the

skin (stage one); if they progress, the skin begins to break down. If

untreated, the skin can break open and the area can become in-

5 fected, causing more and more layers of skin to break down. Even-

tually, muscle will break down, too, until the infection reaches the

bone underneath the skin. This last stage is classified as stage-four

bedsores, which many of Himilce’s bedsores were: her bones were

visible through lesions at her knees and heel.

The medical examiner described Himilce’s skin as “flaky” and

“thick” and observed several healing lesions on her lower legs. The

medical examiner noted that the skin of Himilce’s knees were fused

together, and during the autopsy she had to use a scalpel to cut

Himilce’s legs apart; otherwise, they could not be separated. The

medical experts agreed that the fusion was a result of pressure

sores, caused by the pressure of Himilce’s legs touching each other.

The medical examiner explained that the skin of one leg had

“healed” to the skin of the other leg, causing them to fuse together.

The medical examiner also noted that Himilce’s stomach fat, which

would normally shift back-and-forth, was stuck in place. The medi-

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