Summary
The Georgia Supreme Court affirmed Luther Smith Jr.'s convictions for felony murder and related crimes arising from the death of a 15-month-old child. The court held that the evidence was sufficient for a rational jury to find Smith guilty and that expert testimony concerning whether the child's injuries were consistent with abuse rather than accident was admissible.
Topics
Practice areas
Questions Presented
- Whether the evidence was sufficient to support Smith's felony-murder and other convictions.
- Whether the trial court improperly admitted expert testimony that Deandra's injuries were consistent with abuse rather than accident because the testimony invaded the province of the jury and addressed the ultimate issue.
Holdings
- The evidence was sufficient for a rational jury to find beyond a reasonable doubt that Smith was guilty of the crimes charged.
- A qualified expert may testify that a victim's injuries are consistent with abuse rather than accident, even when that testimony bears on the ultimate factual question and the defendant claims the injuries resulted from an accident.
Key quotations
“There is no question that this difficult determination based on medical knowledge and training is beyond the ken of the jury,” (302 Ga. at 211)
Factual background
Smith was caring for fifteen-month-old Deandra Turner while her mother was away. Deandra was later found unresponsive with extensive blunt-force injuries, including head trauma, retinal and abdominal hemorrhaging, a lacerated liver, and a broken rib. Smith gave inconsistent accounts involving choking on candy, investigators found bloodstained clothing and bedding, and the State's medical and child-abuse experts testified that the injuries were consistent with abusive trauma rather than an accident.
Procedural history
A Fulton County grand jury indicted Smith. Following a jury trial held March 17-26, 2009, he was convicted of felony murder and other crimes and sentenced to life imprisonment. His motion for new trial was denied after a hearing, and the Supreme Court of Georgia affirmed on appeal.