Georgia v. HamiltonAnnotate this Case
In 2011, a jury found Marlina Hamilton guilty of felony murder and other crimes in connection with the shooting death of her ex-husband Christopher Donaldson. In 2015, the trial court granted Hamilton's motion for a new trial on the general and other grounds. At trial, Hamilton argued she shot Donaldson I self-defense and that she suffered from battered-person syndrome. The defense presented an expert witness who testified about battered person syndrome; the State cross-examined the expert but did not present any contrary expert testimony. The State argued that Hamilton had obtained a gun for the purpose of committing an aggravated assault against Donaldson, that she was the initial aggressor in the fatal altercation, and that she did not suffer from battered person syndrome. The jury acquitted Hamilton of malice murder, but found her guilty of the other charges. The trial court then sentenced her to serve life in prison for felony murder and five consecutive years for the firearm charge; the two aggravated assault verdicts merged with the felony murder count. After review, the Supreme Court found that the evidence presented at trial was, when viewed in the light most favorable to the verdicts, legally sufficient to authorize a rational jury to reject Hamilton’s claim of self-defense and find her guilty beyond a reasonable doubt of the crimes for which she was convicted. The State argued that because the evidence was sufficient under the due process standard, the trial court erred in granting a new trial. The Supreme Court held that assertion was incorrect. In this case, the trial court explained that after it carefully reviewed the trial transcript and exhibits and “considered the conflicts in the evidence, the credibility of the witnesses, and the weight of their testimony,” it had concluded that the jury’s guilty verdicts were “decidedly and strongly against the weight of the evidence” and “contrary to the principles of justice and equity.” The court therefore exercised its discretion to grant a new trial. The Supreme Court concluded that the trial court's decision was not an abuse of the trial court’s substantial discretion to act as the “thirteenth juror” in the case. The decision was therefore affirmed and the matter remanded for further proceedings.