Smith v. Georgia
Annotate this CaseAppellant Nakotah Smith challenged his 2019 convictions for malice murder and other crimes in connection with the shooting death of his girlfriend, Crystal Vega. Smith did not dispute that the evidence presented at trial was legally sufficient to support his convictions. Instead, he claimed the trial court erred by admitting hearsay evidence under the residual exception without first explicitly making the determinations required by OCGA 24-8-807 (1) to (3), and that the court improperly relied on cases decided under the old Evidence Code. "Although the better practice is for trial courts to state on the record that each requirement of OCGA 24-8-807 has been met and why," the Georgia Supreme Court concluded that the trial court did not abuse its discretion in failing to do so here. Furthermore, the Court found the record did not show the trial court improperly relied on cases interpreting the old Evidence Code in admitting the challenged hearsay evidence. Accordingly, judgment was affirmed.
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