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Baird v. State

Citations: 411 S.E.2d 332; 201 Ga. App. 378; 1991 Ga. App. LEXIS 1339Docket: A91A1229

Court: Court of Appeals of Georgia; September 30, 1991; Georgia; State Appellate Court

Narrative Opinion Summary

The case concerns a convicted individual, an inmate, who appealed his conviction for escape while armed with a dangerous weapon under OCGA § 16-10-52(b). During the escape attempt at a county jail, the appellant brandished a makeshift weapon, prompting a staff member to comply with his demands due to fear for another guard's safety. On appeal, the appellant argued that the trial court erred by failing to instruct the jury with a definition of 'dangerous weapon,' a request he made during the trial. The appellate court, however, found that the term 'dangerous weapon' is commonly understood and does not require further explanation for the jury, referencing precedents that support the exclusion of definitions for terms widely recognized by laypersons. Consequently, the appellate court upheld the trial court's decision, affirming the conviction. The ruling was concurred by Judges McMurray and Andrews, emphasizing the legal principle that common terms do not necessitate jury instruction definitions.

Legal Issues Addressed

Appeal on Grounds of Jury Instruction Omission

Application: The defendant's appeal based on the omission of a jury instruction definition was denied because the term in question was deemed commonly understood.

Reasoning: Baird's sole argument on appeal contended that the trial court erred by not providing the jury with definitions of 'dangerous weapon,' despite his requests.

Definition of Dangerous Weapon in Criminal Law

Application: The court determined that the term 'dangerous weapon' is commonly understood and does not require additional explanation for the jury.

Reasoning: The court noted that while it is necessary to define technical legal terms that may not be understood by a layperson, the term 'dangerous weapon' is commonly understood and does not require additional explanation.

Jury Instruction on Common Terms

Application: The appellate court affirmed that jury instructions are not required for terms that are in common usage and easily understood by laypersons.

Reasoning: The court referenced previous cases establishing that terms in common usage do not need to be defined for juries.