Woods v. Georgia
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Defendant John Dennis Woods appealed his convictions for malice murder, aggravated assault, possession of a firearm during the commission of a felony, and concealing the death of another, all in connection with the death of Travis Sauls. The evidence authorized the jury to find Woods guilty beyond a reasonable doubt of the crimes for which he was convicted, and the trial court found no ineffective assistance of counsel. However, after review of the record, the Supreme Court found that Defendant presented evidence that he suffered from a mental disease that could have produced a seizure causing a temporary delusion that Sauls posed a threat to his life, even though Sauls may not, in fact, have posed any immediate threat. Defendant filed a written request that the jury be instructed on the law regarding a verdict of not guilty by reason of insanity. During a charge conference, the trial court agreed to give that instruction, as well as certain other written instructions Defendant requested. The next day, immediately before argument, Defendant verbally requested that the jury be instructed on the law regarding self defense using pattern charges; but he had not submitted a written request for such an instruction. The State objected. The trial court stated that the instructions would remain as had been decided during the charge conference. Accordingly, the jury could not determine whether Defendant was suffering from a delusion that satisfied the legal definition without an understanding of what constituted an act that would have been justified, if the circumstances were as Defendant contended he believed them to be, without being instructed as to what conduct would constitute justification. Absent such an instruction, the jury was not provided “with the proper guidelines for determining guilt or innocence.” Accordingly, the Supreme Court concluded that Defendant must be afforded a new trial.
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