Rickman v. State

842 S.E.2d 289, 309 Ga. 38
CourtSupreme Court of Georgia
DecidedApril 20, 2020
DocketS20A0127
StatusPublished
Cited by8 cases

This text of 842 S.E.2d 289 (Rickman 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
Rickman v. State, 842 S.E.2d 289, 309 Ga. 38 (Ga. 2020).

Opinion

309 Ga. 38 FINAL COPY

S20A0127. RICKMAN v. THE STATE.

MELTON, Chief Justice.

Following a jury trial, Victoria Rickman was convicted of

malice murder and a related firearm offense in connection with the

shooting death of William Carter, Jr.1 Rickman appeals, arguing

that she was denied effective assistance of counsel and that the trial

court erred in admitting improper character evidence pursuant to

OCGA § 24-4-404 (b) (“Rule 404 (b)”). We affirm.

1 On December 3, 2013, Rickman was indicted by a DeKalb County grand

jury for malice murder, felony murder predicated on aggravated assault, aggravated assault, and possession of a firearm during the commission of a crime. At a jury trial from August 17 to September 1, 2017, Rickman was found guilty of all charges. She was sentenced to life without parole plus five years for malice murder and possession of a firearm during the commission of a crime. The remaining counts were either vacated by operation of law or merged for sentencing purposes. Rickman filed a motion for new trial on October 12, 2017, which she subsequently amended through new counsel on March 22 and March 27, 2019. After a hearing, the trial court denied the motion on June 14, 2019. Rickman timely filed a notice of appeal; the appeal was docketed to the term of this Court beginning in December 2019 and was thereafter submitted for a decision on the briefs. Viewed in the light most favorable to the jury’s verdict, the

evidence presented at trial established that Rickman and Carter

had a tumultuous on-again, off-again relationship with a history of

verbal and physical abuse, false accusations of sexual assault, empty

threats to obtain temporary protective orders, and numerous calls

to 911. In the days leading up to Carter’s death, the pair was talking

and meeting again despite a recent break-up. Three days before

Carter’s death, however, he called 911 and requested that officers

remove Rickman from his residence. When the police arrived,

Rickman alleged that Carter had hit her; however, Rickman had no

visible injuries. Officers also learned that Rickman had sent text

messages to Carter’s cell phone that included false accusations that

Carter had kidnapped and threatened her. Thereafter, Rickman

was removed from the residence, and Carter told her to never

contact him again.

Then, in the early morning hours of September 13, 2013,

officers responded to a third party’s residence on Clifton Road in

DeKalb County regarding a claim of rape and shots fired. When officers arrived, Rickman was standing in the doorway holding a

small dog; her hair was wet and she had on a clean pair of pajamas.

She did not appear to be injured, and nothing in the home looked

disturbed or out of place. Rickman told the officers, “he raped me

again and I shot him.”

Officers found Carter lying face up on the bed with multiple

gunshot wounds to his body; he was naked, his watch was on the

nightstand, and his gold chain necklace was in his left hand. His

clothes were bunched up on the floor next to the bed, and a pair of

Rickman’s underwear was nearby wrapped around a used tampon.

An autopsy revealed that Carter was shot ten times — four times in

the chest, three times in the back, once in the arm, and twice in the

head. Three of the gunshot wounds had evidence of stippling while

the remaining seven did not. Carter also had bruises to his chin and

left arm, which were likely caused by a blunt object. The medical

examiner concluded that Carter died as a result of his gunshot

wounds.

Rickman was taken to Grady Hospital for a physical examination and a rape kit. Rickman told the treating physician

that Carter forced her to have vaginal sex, after which he restrained

and beat her. Rickman stated that, in order to defend herself, she

grabbed a gun from the nightstand and shot Carter. Though the

vaginal swabbings taken during Rickman’s exam matched a partial

profile of Carter’s DNA, Rickman’s examining physician testified

that he found no injuries on Rickman consistent with her description

of events, and no signs of trauma to her vaginal cavity.

Back at the scene, officers located nine shell casings and one

bullet in the bedroom; the murder weapon, a .40-caliber semi-

automatic firearm, was located inside the drawer of the nightstand

on the side of the bed farthest from Carter’s body. Officers found

blood spatter on the wall, curtains, window, and a pillow on the floor.

Expectorant blood spatter2 was found on the wall closest to Carter’s

feet, and passive blood drops3 were located on Carter’s feet and on

2 Testimony at trial established that this type of blood spatter is caused

by the gunshot wound victim coughing up blood. 3 Testimony at trial established that this type of blood spatter is not

caused by direct or indirect force, but by blood dripping from the body onto another surface. the floor below. Based upon the type, pattern, and location of the

blood spatter on the wall, and the blood flow patterns on Carter’s

face and chest, the State’s crime scene expert opined that Carter was

standing and facing the bedroom wall when he was shot in the back,

after which he fell to the bed and the remaining shots were fired.

Officers also recovered a total of five cell phones during their

investigation — two belonging to Rickman, two belonging to Carter,

and one belonging to an acquaintance of Rickman.4 A forensic

analysis of these phones and relevant cell phone records showed

that, on the evening before the shooting, Rickman exchanged text

messages with the man she was living with, asking him not to come

home because she “[didn’t] want to see a man.” Approximately 30

minutes later, Rickman began communicating with Carter via text

messages and phone calls. During this almost five-hour exchange,

Carter called Rickman the love of his life and indicated that he

wanted to reconcile; however, he also noted that Rickman treated

4 Officers also obtained voluminous cell phone records for the numbers

associated with all five cell phones. him poorly because she constantly called the police and made

allegations against him that were not true. Cell tower data showed

that, around 12:20 a.m. on September 13, Carter’s phone pinged a

tower near Rickman’s house while the two were still talking on the

phone. Thereafter, Rickman’s phone had no activity until 2:14 a.m.,

when she called another male acquaintance, and then 2:16 a.m.,

when she called 911 to report the shooting.

The State also presented evidence of prior difficulties between

Rickman and Carter. Specifically, the State introduced evidence

that in March and April 2012, Rickman sent herself threatening text

messages but made it appear as if Carter had sent them to her. The

State also introduced evidence of incidents from January 20125 and

May 20136 wherein Rickman assaulted Carter and then called the

5 In January 2012, Rickman called the police and alleged that Carter had

held her down and sexually assaulted her. She told officers that she hit Carter in the back of the head with a hammer in order to defend herself. Carter denied the allegations and said that Rickman had “gone crazy.” Carter had a wound to the back of his head and a bite mark on his shoulder. Rickman had red marks on her wrists.

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842 S.E.2d 289, 309 Ga. 38, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rickman-v-state-ga-2020.