Gilreath v. GeorgiaAnnotate this Case
Appellant Christopher Gilreath was convicted by jury of malice murder and associated crimes in connection with the beating death of two-year-old Joshua Pinckney, the son of his live-in-girlfriend, Miriam Pinckney. Gilreath appealed, arguing for the most part that the evidence was insufficient and that he was prevented from presenting a complete defense. The Supreme Court concluded after review that the evidence presented at trial was sufficient to sustain Gilreath's convictions. But the Court found that the trial court abused its discretion in one respect: the State moved the trial court to prohibit Gilreath from eliciting testimony from Pinckney’s ex-husband, who testified as a witness for the State, that Pinckney had a history of threatening both children with physical violence and that, on one occasion, Pinckney slapped a child in the face. The State’s motion in limine was granted, Gilreath made an offer of proof, and the trial court reaffirmed its ruling. "The trial court’s ruling not only hamstrung the defense from rebutting testimony that Pinckney was a good mother, but the ruling also prevented Gilreath from presenting evidence that the only other person in the house at the time had a history of cruel treatment towards her own children. The trial court’s ruling here constituted reversible error." Affirming in part, reversing in part (for malice murder and cruelty to children), the Supreme Court remanded this case for further proceedings.