Watkins v. State

Citations: 711 S.E.2d 655; 289 Ga. 359; 2011 Fulton County D. Rep. 1773; 2011 Ga. LEXIS 474Docket: S11A0348

Court: Supreme Court of Georgia; June 13, 2011; Georgia; State Supreme Court

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Robert Watkins was convicted of malice murder, aggravated assault, conspiracy to commit armed robbery, and possession of a firearm during a crime. The Supreme Court of Georgia affirmed the convictions based on trial evidence, which indicated that on April 21, 2006, Watkins and several accomplices planned a robbery at the China Wok restaurant. After scouting the restaurant, Watkins and another accomplice entered with handguns. They demanded money from cook Guadalupe Parilla, who did not have any, and shot him, while another robber shot Yan Sing Ku, who subsequently died. Following the incident, Watkins expressed concerns about killing someone and threatened his accomplices regarding silence. Testimonies revealed that co-defendant Marcus Brown informed his mother about the robbery and shooting, prompting her to alert the police. Watkins admitted to entering the restaurant intending to commit robbery but claimed he left after hearing gunshots. The court ruled that the evidence was sufficient for a rational jury to find Watkins guilty beyond a reasonable doubt. Additionally, Watkins alleged unconstitutional gender-based discrimination in jury selection, as the prosecution used seven of its eight peremptory strikes against women. However, the jury ultimately included a higher percentage of women than the available pool of potential female jurors, undermining his claim of purposeful discrimination.

The prosecutor accepted approximately 60% of female jurors, and had four remaining strikes, which could have altered the jury composition from ten to eight women. The trial court determined that Watkins did not establish a prima facie case of gender discrimination, affirming that it did not abuse its discretion in this ruling. Watkins also alleged race-based discrimination under Batson v. Kentucky, claiming three of eight peremptory strikes targeted African-American jurors. The trial court required race-neutral justifications for these strikes, which were found to be valid and not pretextual, leading to the affirmation of the denial of Watkins' Batson motion.

Watkins raised three claims of ineffective assistance of trial counsel. To succeed, he must show both deficient performance and that such performance likely changed the trial's outcome. The court can address either component first. Watkins argued that his counsel failed to adequately present expert testimony regarding his mental state during a police statement, but he did not provide sufficient evidence to demonstrate prejudice. Additionally, he claimed ineffective assistance for not moving for a mistrial when the State showed previously disallowed photographs of the victim. However, the court found that the photographs did not add significantly to the evidence presented, and given the case's strength against him, he could not show a reasonable probability that a mistrial would have been granted or that the trial's outcome would differ.

Watkins argued that his trial counsel was ineffective for not objecting to the State's review of his expert's notes during the Jackson-Denno hearing. However, the court found that the counsel's decision was based on a reasonable strategic assessment that the notes were not harmful to Watkins. The court cited Johnson v. State, which establishes that reasonable trial tactics do not constitute ineffective assistance. Additionally, Watkins failed to demonstrate that an objection would have likely changed the outcome of the hearing.

Watkins also contended that the trial court erred in denying his motion to suppress his police statement, asserting that the State did not prove he had made a knowing and voluntary waiver of his Miranda rights. The trial court evaluates the admissibility of statements based on the preponderance of evidence and the totality of circumstances. The expert witness for Watkins claimed he was impaired by drugs at the time of questioning. However, the detective testified that Watkins was coherent, did not show signs of intoxication, and understood his rights as they were read to him. The trial court upheld that Watkins made a knowing and voluntary waiver of his rights, referencing similar cases where courts found valid waivers despite potential intoxication.

The judgment against Watkins was affirmed, with all Justices concurring. The document also notes the timeline of events surrounding Watkins' indictment, trial, sentencing, and subsequent appeal, clarifying that he was found guilty of multiple serious charges, including malice murder, and that his motion for a new trial was denied before he appealed. The court dismissed the State's claim that Watkins was barred from raising certain jury selection issues on appeal, as he had previously joined a co-defendant's challenge.