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Butlerv.The State

CourtSupreme Court of Georgia
Docket No.S20A0870
DecidedSeptember 8, 2020
JudgesSupreme Court of Georgia
Tags
CriminalCriminal LawCriminal ProcedureMurder & MayhemTales From the CryptEvidenceCharacter EvidenceReversalVacaturRemand
Case Summary

Patrick Dela Butler was convicted of malice murder and firearm offenses in the shooting death of Darryl Walden. He challenged the sufficiency of the evidence and the admission of his prior felony conviction during the first stage of the bifurcated trial. The Georgia Supreme Court held that the evidence was sufficient but that the trial court used the wrong standard when admitting the prior conviction. Because the Supreme Court could not say that the evidentiary error was harmless, it vacated Butler’s convictions and remanded for the trial court to apply the correct standard and decide whether the prior conviction should be admitted. The court did not reach Butler’s other evidentiary and ineffective-assistance claims because they might not recur if the trial court orders a new trial. The judgment was therefore vacated without a final ruling on every claim.

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