Charlesv.State
Fred Jason Charles’s girlfriend, Stephanie Daniel, was found shot in his bedroom; the next morning, Charles and a companion were found near her burned SUV, and Charles later made a noose and dared a witness to report him. A jury convicted Charles of malice murder and related offenses, and he appealed denial of his motion for a new trial. The Supreme Court held his sufficiency claim failed because he cited the standard but gave no argument, and the Court no longer reviews sufficiency sua sponte in noncapital murder appeals. It upheld denial of a mistrial over jurors’ possible exposure to the mothers’ brief exchange, finding the remarks expressions of sympathy rather than an admission of guilt and any irregularity harmless beyond a reasonable doubt. The trial court properly denied bifurcation because felon-in-possession charges could serve as the felony-murder predicate, and it twice instructed jurors to limit prior-conviction evidence to relevant counts. Charles’s ineffective-assistance claim about that predicate was moot because the felony-murder conviction was vacated by operation of law. The judgment was affirmed; the felony-murder conviction and other counts were merged or vacated for sentencing.
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