Robinson v. State

Supreme Court of Georgia · 2020 · Evidence

848 S.E.2d 441

Updated July 19, 2026

evidencesufficiency of the evidenceother-acts evidenceexpert testimonyultimate issuemerger and sentencingJackson v. VirginiaOCGA 24-14-6

Facts

Robinson lived with Summer Sanchez and her children, including four-year-old Lalia and three-year-old N. H. Lalia died after being taken to the hospital, and the medical examiner determined that the cause of death was blunt force injury to the abdomen; N. H. was later found to have abdominal bruising and adult bite marks, which Dr. Donna Evans testified were consistent with abuse and likely inflicted the night before hospital admission. Sanchez testified that Robinson had punched the boys in the chest and had explained N. H.'s bite marks by saying he had been playing with her and bit too hard. A jailhouse informant testified that Robinson said he 'did it' because he was mad at Sanchez, referring to the slaying of Lalia, and also said he wanted to end his life because of the guilt.

Issue

Whether the evidence was sufficient to support Robinson's convictions, whether any error in admitting evidence of a prior violent act against Sanchez required reversal, and whether Dr. Evans's testimony about the bite marks was inadmissible because it addressed matters within common understanding or improperly embraced an ultimate issue.

Rule

Under Jackson v. Virginia, evidence is sufficient if a rational trier of fact could find guilt beyond a reasonable doubt, and under OCGA § 24-14-6 circumstantial evidence must exclude every reasonable hypothesis other than guilt, though reasonableness of alternative hypotheses is principally for the jury. A confession is direct evidence of guilt and means the case is not purely circumstantial. Under OCGA § 24-4-404 (b), other-acts evidence is admissible only if it is relevant to a non-character issue, its probative value is not substantially outweighed by unfair prejudice, and there is sufficient proof by a preponderance that the defendant committed the act. Expert testimony is admissible if it concerns matters beyond the ken of the average layperson, and under OCGA § 24-7-704 (a) it may embrace an ultimate issue so long as it does not state an opinion about whether the accused had the mental state or condition constituting an element of the crime under OCGA § 24-7-704 (b).

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Macon, Georgia, two-year-old Ava Cole died from internal abdominal injuries while living with her mother, Tessa Cole, and Tessa's boyfriend, Darnell Price. A jail inmate testified that Darnell said, "I did it because I was furious at Tessa," and explained that he was talking about Ava's death.

Darnell argues on appeal that the prosecution's case was wholly circumstantial and failed to exclude the reasonable hypothesis that Tessa caused Ava's death. Which is the strongest response?

Explanation. A defendant's confession is direct evidence of guilt. Under the majority opinion, a statement admitting the killing itself is not merely an incriminating admission, so the case is not purely circumstantial for purposes of the circumstantial-evidence rule. The presence of another possible actor does not convert direct evidence into circumstantial evidence. (Derived from Robinson v. State (n.d.).)