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Woodard v. State
Citations: 586 S.E.2d 330; 277 Ga. 49; 2003 Fulton County D. Rep. 2745; 2003 Ga. LEXIS 725Docket: S03A0767
Court: Supreme Court of Georgia; September 15, 2003; Georgia; State Supreme Court
James Woodard was convicted of murder and felony murder in the shooting death of Max Rister and sentenced to life imprisonment. He appealed the denial of his motion for a new trial, arguing that the trial court improperly admitted his police statement and denied his motion for mistrial regarding character evidence. The evidence presented at trial indicated that Rister was shot by Woodard, who, along with an accomplice, attempted to rob him at a hotel. Rister identified Agnew as a participant but noted Woodard was the shooter. The court found this evidence sufficient for a conviction. Woodard challenged the admission of his police statement, claiming it was not voluntarily given due to his age (17 years, 10 months) and lack of parental involvement during interrogation. However, the trial court determined that Woodard was read his Miranda rights, signed a waiver, and that the statement was made voluntarily without coercion. The court cited that individuals over 17 are no longer treated as juveniles under Georgia law, and upheld the trial court's factual findings regarding the statement's admissibility. Additionally, Woodard sought a mistrial based on Detective Brantley’s testimony, which he claimed improperly affected his character. The court ruled that the non-responsive answer did not improperly place Woodard's character in issue and upheld its broad discretion in denying the mistrial. The Supreme Court of Georgia affirmed the trial court's decisions, concluding that no errors occurred in the admission of evidence or the handling of the mistrial motion. All Justices concurred in the judgment. On July 7, 1994, a crime occurred that led to the victim's death on November 7, 1994. Woodard, also known as Charlie Coon, was indicted for murder and felony murder on January 10, 1995, in Laurens County. He was found guilty on May 1, 1996, with sentencing occurring on May 3, 1996. A motion for a new trial filed on May 22, 1996, was denied on December 5, 2002. Woodard filed a notice of appeal on January 6, 2003, which was initially docketed in the Court of Appeals on January 31, 2003, and subsequently transferred to the higher court on February 6, 2003, for a decision based on briefs. In a statement, Woodard recounted being in a car with three others, including Agnew, when shots were fired after Agnew and one companion exited the vehicle, prompting them to flee the scene. During cross-examination, defense counsel inquired about Agnew's criminal activities in Laurens County, but Detective Brantley refrained from addressing the question directly, instead noting that the arrests of Agnew, Woodard, and others were linked to several similar criminal cases.