Thrift v. State

852 S.E.2d 560, 310 Ga. 499
CourtSupreme Court of Georgia
DecidedDecember 7, 2020
DocketS20A1182
StatusPublished
Cited by17 cases

This text of 852 S.E.2d 560 (Thrift 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
Thrift v. State, 852 S.E.2d 560, 310 Ga. 499 (Ga. 2020).

Opinion

310 Ga. 499 FINAL COPY

S20A1182. THRIFT v. THE STATE.

MCMILLIAN, Justice.

Craig Lester Thrift was convicted of felony murder in

connection with the death of Terry Rouse.1 On appeal, Thrift

contests the sufficiency of the evidence to support his conviction; the

denial of his motion for new trial on the general grounds; the denial

of five motions for mistrial; the admission of certain evidence

presented by the State; the exclusion of certain evidence offered by

the defense; and the restriction of his attorney’s cross-examination

of one of the State’s witnesses. Additionally, Thrift asserts that he

1 Rouse disappeared on May 11, 1991, and Thrift was indicted for his

murder by a Ware County grand jury almost 21 years later, on April 3, 2012. The indictment charged Thrift with one count of malice murder and one count of felony murder based on aggravated assault. Thrift was tried from April 14 to 17, 2014, and the jury acquitted him of malice murder but found him guilty of felony murder. The trial court sentenced him to life in prison. Thrift filed a motion for new trial on April 23, 2014, and amended that motion on January 26, 2017, and again on July 6, 2017. The trial court denied Thrift’s motion as amended on February 7, 2019, and Thrift timely filed a notice of appeal. The case subsequently was docketed to the August 2020 term of this Court and submitted for a decision on the briefs. is entitled to a new trial under a cumulative error analysis. We

affirm for the reasons set forth below.

1. Thrift asserts that the evidence at trial was insufficient to

support his conviction for felony murder. In evaluating whether the

evidence at trial was sufficient as a matter of due process under the

Fourteenth Amendment of the United States Constitution, this

Court considers whether a rational trier of fact could have found the

defendant guilty beyond a reasonable doubt. See Jackson v.

Virginia, 443 U.S. 307, 319 (III) (B) (99 SCt 2781, 61 LE2d 560)

(1979). In performing this evaluation, we view the evidence in the

light most favorable to the verdict, leaving “to the jury the resolution

of conflicts or inconsistencies in the evidence, credibility of

witnesses, and reasonable inferences to be made from the evidence.”

Rodriguez v. State, 309 Ga. 542, 546 (1) (847 SE2d 303) (2020)

(citation and punctuation omitted).

Viewed in that light, the evidence at trial showed that Rouse

was Thrift’s cousin and best friend. In 1991, the two men worked

together pouring concrete for Thrift’s father’s company. Rouse

2 customarily picked Thrift up at Thrift’s house, and they rode to work

together. In May 1991, Thrift was married to Rhonda Thrift, and

Rouse was having an affair with her. On the afternoon of Friday,

May 10, 1991, Rouse and Rhonda met up at the home of a friend.

That night, Rhonda and the friend went to a party along with Thrift.

When they arrived at the party, Rouse was already there. The

Thrifts and the friend left the party about 25 to 30 minutes after

arriving and headed to the Thrifts’ home, making a couple of stops

along the way. The party broke up early on the morning of Saturday,

May 11. At around 4:00 that morning, Rouse, who had stayed at the

party, was seen sleeping in his car in front of the house where the

party took place, but his car was gone by 7:00 a.m.

Thrift, Rouse, and two other men were scheduled to pour

concrete at a jobsite at 7:00 a.m. that Saturday morning. After

attending a different party, the two other men drove to the Thrifts’

house sometime in the early morning hours and slept in their car in

the Thrifts’ front yard so they would not be late to the job site. The

Thrifts’ babysitter, who slept on the Thrifts’ couch that night,

3 reported hearing Rhonda and Thrift arguing during the night; being

awakened later by a loud noise, perhaps the sound of a horn or a

loud muffler; and seeing Rouse there when she woke up between

5:00 and 6:00 a.m. Sometime before 7:00 a.m., the two men who were

sleeping in their car were awakened by either Thrift or Rhonda, and

they left with Thrift, arriving at the job site by 7:00 a.m. Rouse never

showed up to work that day.

At around 2:00 p.m. that day, Rouse’s car was discovered

outside one of the entrances to the Okefenokee Swamp. The car’s

windows were rolled down, the ignition switch was in the on

position, the battery was dead, and the car was out of gas. Rouse’s

family never saw or heard from him again. In the 20 years following

Rouse’s disappearance, Thrift told a number of people on numerous

occasions that he had killed Rouse by beating him and/or shooting

him because Rouse was having an affair with Rhonda. Thrift said he

then disposed of Rouse’s body in the swamp, sometimes describing

Rouse as “gator bait.”

Thrift contends that this and other evidence at trial was

4 insufficient to support the verdict because, although Rouse has not

been seen by his family since May 11, 1991, his body has never been

found, no crime scene was ever discovered to show that Rouse died

as the result of any criminal action, and other evidence showed that

Rouse disappeared of his own volition.2 Thrift argues that even

giving the appropriate deference to the jury, no rational factfinder

could find that Rouse was even dead, much less that he died as the

result of criminal conduct, or that it was Thrift who killed him.

“It is of course true that the burden was upon the State to prove

the corpus delicti, and to show also that the defendant was the

perpetrator of the alleged offense. Both of these elements, however,

could be shown by circumstantial as well as direct evidence.” White

v. State, 263 Ga. 94, 96-97 (1) (428 SE2d 789) (1993) (citation and

2 One of Rouse’s co-workers testified that the week before Rouse disappeared, Rouse said that he was about to leave and that no one would be able to find him. Rouse explained that he had an upcoming court date with the potential for jail time and he owed people a lot of money. Additionally, on the afternoon before he disappeared, Rouse asked Rhonda never to forget him. Three witnesses testified that they knew Rouse and had seen him after his disappearance. The three witnesses each reported seeing Rouse, or someone who looked like him, after May 11, 1991, but none of those individuals actually spoke with the person they identified as Rouse. 5 punctuation omitted). See also Richardson v. State, 276 Ga. 548, 549

(1) (580 SE2d 224) (2003) (proof beyond a reasonable doubt of the

corpus delicti, which means “the body of the crime,” may be

established by indirect as well as direct evidence). Moreover, “[t]o

establish the corpus delicti in a homicide prosecution, the State

must prove that a death occurred, but there is no requirement that

a dead body be produced.” Richardson, 276 Ga. at 549 (1).

Here, Thrift stated on a number of occasions to a number of

different witnesses that he killed Rouse by beating him, shooting

him, or both, and then disposed of his body in the swamp, because

Rouse was having an affair with Rhonda. Each of these statements

“made not a mere incriminating admission, but a confession, which

is direct evidence of his guilt, and this is not, therefore, a purely

circumstantial case.” Robinson v. State, 309 Ga. 729, 731 (1) (a) (848

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