Chatman v. Brown
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In May 1999, a jury found Derrick Brown guilty of kidnapping with bodily injury, aggravated assault upon a person 65 years or older, robbery by force, and burglary in connection with the beating and robbing of Margaret Logan. Brown’s convictions were upheld on appeal. In December 2008, Brown sought habeas relief based on the Supreme Court’s then-controlling decision in "Garza v. State," (670 SE2d 73)(2008)), which established new factors for assessing the asportation element as required for kidnapping. Brown also sought habeas relief based on "Brodes v. State," (614 SE2d 766)(2005)), alleging error in the jury instructions for the reliability of Logan’s identification. Analyzing the Garza factors, the habeas court granted relief and set aside the conviction and sentence for kidnapping. The habeas court denied relief on Brodes grounds, finding that Brodes announced a new procedural rule that did not apply retroactively. The warden appealed the habeas court’s ruling on the Garza issue, and Brown appealed the habeas court’s ruling on the Brodes issue. Upon review, the Supreme Court reversed the habeas court in the warden's appeal, and affirmed the lower court in Brown's appeal on the Brodes issue.
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