Georgia v. Hamilton
Annotate this CaseIn 2015, appellee Paul Hamilton was indicted for the malice murder of Brandon Lay, the felony murder of Lay predicated on aggravated assault, and the aggravated assaults of Lay, Teddi Taylor, and Judy Hewatt. In 2018, a jury found Hamilton not guilty of malice murder but guilty of the remaining crimes. On October 25, 2018, the trial court, on its own motion, granted Hamilton a new trial on general and legal grounds. The State appealed, contending the trial court erred in granting Hamilton a new trial on the general grounds because the trial court erred by applying the legal standard for the sufficiency of the evidence laid out in Jackson v. Virginia, 443 U.S. 307, 319 (99 SCt 2781, 61 LE2d 560) (1979), instead of weighing the evidence as the thirteenth juror. The Georgia Supreme Court determined this contention was without merit and affirmed. Although the trial court did briefly mention the Jackson v. Virginia standard at the hearing at which it granted a new trial, it quickly followed that statement with the correct standard for the general grounds and by stating that it would grant a new trial based on those standards. Specifically, the court stated that it was “sitting as the 13th juror,” that the evidence “at trial was decidedly and strongly against the weight of the evidence,” and that “a new trial is consistent with the principles of equity and justice.”
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