Bennett v. State

Summary

The Georgia Supreme Court affirmed Archie Edward Bennett’s convictions for felony murder, arson, and concealing a death. The court held that evidence of drugs found in the victim’s system was properly excluded absent competent evidence linking the drugs to her behavior, and that the record did not establish a violation of Bennett’s right to be present at trial.

Holdings

1. Evidence that a murder victim ingested drugs is inadmissible without competent evidence explaining how the substances affected the victim's behavior at the pertinent time. Because Bennett presented no such evidence, the trial court properly excluded the drug evidence.
2. The defendant did not demonstrate a violation of his right to be present because the record showed his presence on each trial day and contained no affirmative evidence that he was absent after the recesses.
3. The evidence was sufficient to authorize a rational jury to reject Bennett's changing accounts and find him guilty beyond a reasonable doubt of felony murder, arson, and concealing a death.

Questions Presented

1. Whether the trial court abused its discretion by excluding evidence that the victim had Phentermine and Hydrocodone in her system when the defendant presented no expert or other competent evidence connecting the drugs to the victim's behavior.
2. Whether the defendant's constitutional right to be present at trial was violated because the transcript did not expressly state that he was present after three recesses.
3. Whether the evidence was sufficient to support the convictions for felony murder, arson, and concealing a death.

Disposition

affirmed