Colton v. Georgia
Annotate this CaseA jury found defendant guilty of malice murder, felony murder, aggravated assault, and aggravated battery in connection with the 2002 beating death of Shannon Blount, and he was sentenced to life imprisonment. In a prior direct appeal to the Supreme Court, defendant contended that his confession was erroneously admitted into evidence at trial without a preliminary finding by the trial court that the confession was voluntary, and that the trial court erred by allowing police officers to testify regarding two separate statements made to them by non-testifying co-defendant Rayford Bussie that incriminated defendant because the admissions violated the Confrontation Clause of the Sixth Amendment. The Supreme Court found that there was sufficient evidence to enable a rational trier of fact to find defendant guilty beyond a reasonable doubt of the crimes for which he was convicted; however, it was necessary to remand the case to the trial court for a proper consideration of whether defendant's confession was made voluntarily because although the jury made the express finding on the verdict form that the confession was indeed voluntary, the trial court failed to make a preliminary and conclusive finding in that regard. In a second appeal, defendant appealed the trial court's ruling that his confession which was in evidence at his trial was voluntary. Finding no reversible error in this decision, the Supreme Court affirmed.
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