Brandon Haywood v. The State

Summary

The Supreme Court of Georgia affirmed Brandon Haywood’s convictions for malice murder arising from the shooting death of Marcus Braswell. The court held that the prosecutor’s explanations for peremptory strikes were facially race-neutral under Batson and that Haywood failed to show discriminatory intent. The court also held that his claim concerning an involuntary-manslaughter instruction was moot as to felony murder and harmless as to malice murder.

Holdings

1. The trial court did not clearly err in denying Haywood's Batson challenge because the prosecutor offered facially race-neutral explanations for the challenged strikes, including prospective jurors' employment status, demeanor, and lack of eye contact, and Haywood failed to establish discriminatory intent.
2. Haywood's challenge to the refusal to instruct on involuntary manslaughter as a lesser-included offense of felony murder was moot because the felony-murder count was vacated by operation of law. To the extent he challenged the refusal to instruct on involuntary manslaughter as a lesser-included offense of malice murder, any error was harmless because the malice-murder verdict necessarily reflected the jury's finding that Haywood intended to kill Braswell.

Questions Presented

1. Whether the trial court erred in denying Haywood's Batson challenge to the State's use of all nine peremptory strikes against Black prospective jurors.
2. Whether the trial court erred by refusing to instruct the jury on involuntary manslaughter as a lesser-included offense of felony murder or malice murder.

Disposition

affirmed