Giddens v. GeorgiaAnnotate this Case
Appellant Matdrick Giddens was found guilty of five crimes, including two counts of felony murder, in connection with the shooting death of Timothy Murray, Jr. After the trial court granted Giddens' motion for new trial based on two instructional errors, he filed a plea in bar seeking dismissal of the case based on his constitutional protection against double jeopardy. The trial court denied the plea in bar, and Giddens appealed that ruling. He argued the evidence at his trial was insufficient to support the guilty verdicts and that collateral estoppel barred the State from retrying him for the crimes of which he was found guilty, because he was acquitted of the aggravated assault count that was a predicate element of all of those crimes. After review, the Supreme Court concluded that the evidence was sufficient to support the guilty verdicts. As for the collateral estoppel issue, the Georgia Court noted that the United States Supreme Court granted certiorari to decide this very question, which divided the lower courts. The Georgia Court determined the U.S. Supreme Court's decision would be released after its two-term deadline for deciding this case, it worked through the constitutional question. After doing so, the Georgia Court joined the majority position and rejected Giddens' argument. The Court therefore affirmed the trial court’s judgment.