Mayo v. State, 277 Ga. 645

Summary

The Supreme Court of Georgia held that the evidence was sufficient to support Terrance Lamar Mayo's convictions for malice murder, aggravated assault, and possession of a firearm during the commission of a crime. Because malice murder is a capital felony that must be prosecuted by indictment, the court held that proceeding under an accusation deprived the trial court of subject-matter jurisdiction and reversed the malice-murder conviction while affirming the remaining convictions.

Holdings

1. The evidence was constitutionally sufficient to support Mayo's convictions because a rational trier of fact could have found beyond a reasonable doubt that he committed the charged offenses.
2. A capital felony prosecution must proceed under an indictment, and a trial court lacks subject-matter jurisdiction to adjudicate a capital felony charged only by accusation.
3. The aggravated-assault and firearm-possession convictions were valid because those offenses were not capital felonies and could properly proceed under an accusation with Mayo's consent.

Questions Presented

1. Whether the evidence was sufficient to support Mayo's convictions.
2. Whether the trial court had subject-matter jurisdiction to adjudicate the malice-murder charge when the prosecution proceeded under an accusation rather than an indictment.
3. Whether Mayo's consent to proceeding under an accusation could confer subject-matter jurisdiction over a capital felony charge.

Disposition

other