Treadaway v. State

843 S.E.2d 784, 308 Ga. 882
CourtSupreme Court of Georgia
DecidedJune 1, 2020
DocketS20A0410
StatusPublished
Cited by14 cases

This text of 843 S.E.2d 784 (Treadaway 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
Treadaway v. State, 843 S.E.2d 784, 308 Ga. 882 (Ga. 2020).

Opinion

308 Ga. 882 FINAL COPY

S20A0410. TREADAWAY v. THE STATE.

MCMILLIAN, Justice.

Dora Treadaway was convicted of felony murder in connection

with the death of her husband Claude “Randy” Treadaway.1 On

appeal, Treadaway argues that the trial court’s summary order

denying her motion for new trial should be vacated and remanded

for additional factual findings, that the State failed to prove beyond

a reasonable doubt that Treadaway committed any unlawful act

1 The crimes occurred on August 1, 2009. On January 4, 2010, a Chattooga County grand jury indicted Treadaway for malice murder, felony murder predicated on aggravated assault, voluntary manslaughter, and aggravated assault. At a trial held from February 22 to February 26, 2010, a jury found Treadaway not guilty of malice murder and voluntary manslaughter but guilty of felony murder and aggravated assault. The trial court merged the aggravated assault into the felony murder conviction and sentenced Treadaway to serve life in prison. Treadaway filed a motion for new trial on March 1, 2010, which she amended through new counsel on March 19, 2019, and March 28, 2019. Following a hearing, the trial court denied Treadaway’s motion (as amended) on July 17, 2019, and her motion for reconsideration on August 9, 2019. Treadaway filed a notice of appeal to this Court; this case was docketed to the term beginning in December 2019 and was orally argued on February 12, 2020. that proximately caused Randy’s death, that the trial court’s jury

instructions on causation were erroneous, and that trial counsel was

ineffective in relying on cross-examination of the State’s medical

expert rather than calling a defense expert witness and in failing to

request the proper charge on causation. We disagree and affirm

Treadaway’s convictions.

Viewed in the light most favorable to the jury’s verdicts,2 the

evidence showed that Dora and Randy Treadaway were married and

lived together in Chattooga County. Testimony from several

witnesses indicated that both were heavy drinkers — Randy was a

chronic alcoholic — and that Treadaway was often violent toward

Randy.

On the afternoon of August 1, 2009, Terry Trapp drove with his

mother to the Treadaways’ residence for a social visit. Upon

arriving, Trapp heard Treadaway and Randy arguing loudly, so

Trapp and his mother opted to visit Wayne Posey, a neighbor who

2 See Jackson v. Virginia, 443 U.S. 307, 319 (III) (B) (99 SCt 2781, 61

LE2d 560) (1979). lived in his own mobile home on the Treadaways’ property. Shortly

thereafter, a visibly intoxicated and “very mad” Treadaway went

inside Posey’s home and announced, “[H]e’s going to quit drinking

one way or the other and I mean it.” Treadaway left but later

returned with a broom in her hand, stating, “I believe I’ve done it

this time, I think I killed him.” Treadaway announced that she had

beaten Randy with the broom handle.3

Trapp went over to the Treadaways’ home to investigate and

discovered Randy lying on his right side in an empty bathtub. Randy

was naked and in the fetal position. Feeling no pulse and seeing that

Randy had turned pale blue, Trapp yelled for help. Posey came over,

and he and Trapp pulled Randy out of the bathtub and performed

CPR while Trapp’s mother called 911. Posey observed that Randy’s

hair was wet and his body was “moist.” During this time, Treadaway

was “screaming and crying [about] how much she loved Randy

and . . . couldn’t believe it had happened.” When emergency

3 The handle of the broom had previously been replaced with the shaft of

a metal “weed eater.” responders arrived, Treadaway stated that she was tired of Randy’s

drinking and that she had hit him in the back of his head with the

broom handle and killed him. Chattooga County deputies observed

Treadaway, who was “really intoxicated [and] could[ ] hardly stand

up,” sitting on the trailer steps crying and saying over and over

again “Randy’s dead and I killed him.”

Treadaway was taken into custody that evening but was not

interviewed due to her apparent intoxication. The following day,

after she was advised of her rights under Miranda,4 Treadaway

denied that she and Randy had been arguing, denied hitting him

with a broom that day (although she admitted hitting him with a

broom in the past), and claimed that she found Randy lying on the

bathroom floor right around the time that Trapp and his mother

arrived at the home.

A medical examiner with the Georgia Bureau of Investigation

testified that, at the time of autopsy, Randy had fluid in his stomach,

enlarged lungs, and multiple blunt-force injuries to his back, neck,

4 Miranda v. Arizona, 384 U.S. 436 (86 SCt 1602, 16 LE2d 694) (1966). and head that had been inflicted immediately prior to his death. The

medical examiner also noted that Randy had reportedly expelled

approximately one cup of odorless fluid when rolled over at the

scene.5 The medical examiner opined that Randy died due to

drowning and blunt-force trauma and also concluded that Randy’s

history of alcoholism and blood alcohol content — which was at least

0.4 grams at the time of his death — though not fatal, were

circumstances contributing to Randy’s death.

The State also presented evidence that Randy, who weighed

126 pounds at the time of his death, had lost all the fingers on his

right hand in an industrial accident as a teenager. In addition, he

had recently broken both of his feet in an accident and was suffering

from significantly reduced mobility, having to “scoot on his bottom”

to move around the home.

1. Treadaway contends that the State failed to prove beyond a

reasonable doubt that she committed any unlawful act that

proximately caused Randy’s death. In considering Treadaway’s

5 A sheriff’s officer subsequently testified to that fact. challenge to the sufficiency of the evidence, our review is limited to

whether the trial evidence, when viewed in the light most favorable

to the verdicts, is sufficient to authorize a rational trier of fact to

find the defendant guilty beyond a reasonable doubt of the crimes of

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

(III) (B) (99 SCt 2781, 61 LE2d 560) (1979). “Under this review, we

must put aside any questions about conflicting evidence, the

credibility of witnesses, or the weight of the evidence, leaving the

resolution of such things to the discretion of the trier of fact.” Mims

v. State, 304 Ga. 851, 853 (1) (a) (823 SE2d 325) (2019) (citation and

punctuation omitted).

“[T]he felony murder statute requires only that the defendant’s

felonious conduct proximately cause the death of another person.”

State v. Jackson, 287 Ga. 646, 660 (6) (697 SE2d 757) (2010).

“Proximate causation imposes liability for the reasonably

foreseeable results of criminal conduct if there is no sufficient,

independent, and unforeseen intervening cause.” Frazier v. State,

(308 Ga. __, __ (2) (a) (841 SE2d 692) (2020) (citations and punctuation omitted). An unlawful injury is the proximate cause of

death when:

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843 S.E.2d 784, 308 Ga. 882, Counsel Stack Legal Research, https://law.counselstack.com/opinion/treadaway-v-state-ga-2020.