SCOGGINS v. THE STATE
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In July 2015, Christopher Reid Scoggins and co-defendant Fred Jason Charles were indicted for the murder of Stephanie Daniel and other related offenses. The jury found both defendants guilty on all counts. Scoggins was sentenced to life without parole for malice murder, plus additional time for other crimes. Scoggins appealed, arguing that the evidence was insufficient to support his convictions and that his trial counsel was ineffective for failing to request a jury instruction on concealing the death of another or hindering the apprehension of a felon.
The Supreme Court of Georgia affirmed the lower court's ruling. The court held that the evidence was sufficient to sustain Scoggins' convictions. Even though it was not conclusively established which defendant shot Daniel, the court found sufficient evidence of Scoggins' involvement in the crime. This was based on the fact that Scoggins was present at the time of the shooting, fled the scene with Charles, and made no attempt to seek medical aid for Daniel, which the court viewed as an indication of shared criminal intent.
Additionally, the court held that Scoggins' trial counsel was not ineffective. The court stated that neither concealing the death of another nor hindering the apprehension of a felon were included within any of the offenses with which Scoggins was charged. Therefore, it was not deficient for Scoggins' trial counsel to not request instructions on these offenses.
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