Weems v. State

CourtSupreme Court of Georgia
DecidedJanuary 17, 2024
DocketS23A1179
StatusPublished

This text of Weems v. State (Weems 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
Weems v. State, (Ga. 2024).

Opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.

In the Supreme Court of Georgia

Decided: January 17, 2024

S23A1179. WEEMS v. THE STATE.

PINSON, Justice.

On the morning of June 3, 2018, a motorist driving down Brom-

ack Drive in Fulton County saw a man lying in the front yard of a

home, covered in blood and shaking back and forth. She called 911,

and the man in the yard, Christopher Welch, was taken to the hos-

pital where he died of blood loss from a gunshot wound to his head.

As part of the investigation of Welch’s shooting, the police entered

the home that Welch was found in front of, and law enforcement

found Welch’s girlfriend, Chloe Dowdy, shot to death in one of the

bedrooms. That bedroom belonged to Rufus Weems, who was later

convicted of two counts of malice murder and other crimes related to Welch’s and Dowdy’s deaths. 1

On appeal, Weems raises several claims. He contends that the

evidence was not sufficient to sustain his convictions as a matter of

constitutional due process, and under OCGA § 24-14-6 because the

State failed to exclude every other reasonable hypothesis of guilt be-

yond a reasonable doubt. He challenges the trial court’s denial of his

motion for new trial on the “general grounds” under OCGA §§ 5-5-

1 The shootings occurred on the morning of June 3, 2018. On September

14, 2018, a Fulton County grand jury returned an indictment charging Weems with malice murder of Dowdy (Count 1), malice murder of Welch (Count 2), felony murder of Dowdy predicated on aggravated assault with a deadly weapon (Count 3), felony murder of Welch predicated on aggravated assault with a deadly weapon (Count 4), felony murder of Dowdy predicated on posses- sion of a firearm by a convicted felon (Count 5), felony murder of Welch predi- cated on possession of a firearm by a convicted felon (Count 6), aggravated as- sault of Dowdy (Count 7), aggravated assault of Welch (Count 8), possession of a firearm during commission of a crime (Count 9), and two counts of possession of a firearm by a convicted felon (Counts 10, 11). At a jury trial from November 4, 2019, to November 14, 2019, the jury returned guilty verdicts on Counts 1- 10 (the State nolle prossed Count 11). The trial court sentenced Weems to con- current life sentences without parole for the malice murders of Dowdy and Welch (Counts 1 and 2); five years without parole, consecutive to Count 2, for possession of a firearm during the commission of a felony (Count 9); and five years without parole, consecutive to Count 9, for possession of a firearm by a convicted felon (Count 10). The remaining counts either merged or were va- cated by operation of law. Weems, through trial counsel, filed a timely motion for new trial on December 5, 2019, which he amended through new counsel multiple times. Weems waived hearing on the motion for new trial and, on March 31, 2023, the trial court denied the motion as amended. Weems filed a timely notice of appeal on April 28, 2023. His appeal was docketed to the Au- gust 2023 term of this Court and submitted for a decision on the briefs. 2 20 and 5-5-21. And he claims the trial court erred by not allowing a

witness to testify remotely and by commenting on the evidence.

Each claim fails. The evidence was sufficient to support

Weems’s convictions as a matter of constitutional due process, and

it authorized the jury to reject Weems’s hypothesis that someone

else was the shooter. As for the trial court’s ruling on the general

grounds, Weems has not established that the trial court applied the

wrong standard, and his argument is otherwise not properly before

us. The trial court was required to deny his motion for remote testi-

mony under the relevant Superior Court rule after the State ob-

jected. And Weems has not shown that the trial court’s repeating of

a witness’s testimony while ruling on an objection was an improper

comment on the evidence. So Weems’s convictions and sentence are

affirmed.

1. The evidence at trial, viewed in the light most favorable to

the verdicts, showed the following. At the time of the shooting,

Weems was staying in a spare room at the home of Lakesha Reed,

who lived with her children, her mother (Carrie Reed) and her

3 brother (James Jordan III) on Bromack Drive in Fulton County. On

the night of June 2, 2018, all of them, including Weems, ordered

pizza and watched a movie at home. By 1:00 a.m. on June 3, 2018,

everyone had gone to bed—Lakesha, Carrie, and Weems in their re-

spective bedrooms (with the children split between Lakesha’s and

Carrie’s rooms) and Jordan on the couch in the living room. In the

early hours of that morning, Jordan woke up because someone was

walking from the hall bathroom to Weems’s room with a flashlight.

Jordan did not see who this was. Separately, Lakesha saw a

stranger, who was using his phone as a flashlight, walk into the hall-

way bathroom that was across from her bedroom. She later identi-

fied the stranger as one of the shooting victims, Christopher Welch.

Still later that morning, close to sunrise, Jordan saw Weems

leave and return with another man and go into Weems’s bedroom.

After Weems’s bedroom door closed, Jordan heard gunshots.

Lakesha and Carrie also heard the gunshots and hid in Carrie’s

bathroom with Jordan and the children. While in the bathroom,

Lakesha and Carrie each looked out a window and saw Weems—

4 who they each described as wearing a white tank top and basketball

shorts—get into his car and drive away. Jordan did not see Weems

when he looked out the window, but he saw Weems’s car driving

away.

Around 7:00 a.m. on June 3rd, Cynthia Johnson drove past

Lakesha’s home, heard gunshots, and saw two men leave the home.

One of the men had a dark complexion and a “low haircut” and was

wearing a white T-shirt and shorts and carrying a handgun; she saw

him get into a car. The other man walked around the side of the

building. After seeing this, Johnson stopped at a gas station for a

few minutes, then got back in her car and drove by Lakesha’s home

again, where she saw Welch lying on the ground, covered in blood

and shaking. Johnson stopped and called 911. She did not think that

Welch was one of the two men she saw leaving the home earlier that

morning. In the meantime, Lakesha, Carrie, and Jordan left their

hiding place in Carrie’s bathroom after they heard a woman outside

the home scream. They saw blood throughout the hallway leading to

the front door.

5 Soon after, the police arrived. Welch was taken to the hospital,

where he died of blood loss from a gunshot wound. At trial, the med-

ical examiner explained that Welch had suffered two gunshot

wounds—one to his hand, which was not fatal, and a second to his

head, which caused him to bleed to death.

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