Butler v. Georgia
Annotate this CaseAppellant Patrick Butler challenged his 2011 convictions for malice murder and two firearms offenses in connection with the shooting death of Darryl Walden. Appellant argued on appeal: (1) that the evidence presented at trial was legally insufficient to support his convictions; (2) the trial court made several evidentiary errors, and (3) that he was denied the effective assistance of counsel. After review, the Georgia Supreme Court determined the evidence presented at trial was legally sufficient to support his convictions. However, the trial court applied the wrong standard in admitting evidence of Appellant’s 2005 felony conviction for obstructing a law enforcement officer during the first stage of the bifurcated trial, and the Supreme Court could not say that the admission of the evidence was harmless. Accordingly, the Court vacated Appellant’s convictions, and remanded the case to the trial court to apply the correct standard and determine whether the prior felony conviction should have been admitted. The Court did not address Appellant’s other enumerations of error at this time.
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