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Perraultv.State

CourtSupreme Court of Georgia
Docket No.S23A0379
DecidedMay 2, 2023
Reporter316 Ga. 241; 887 S.E.2d 279; 2023 Ga. LEXIS 87
JudgesMCMILLIAN, Justice. All the Justices concur.
Tags
CriminalMurderVenueDomestic ViolenceCumulative ErrorSufficiency of the EvidenceLaw Enforcement DefendantTales From the CryptMurder & MayhemDomestic DreadState Violence & Death
Case Summary

Michael Seth Perrault, an off-duty police officer, was convicted of malice murder and family-violence battery after his wife, Amanda, died from a gunshot wound six days after reporting that he had choked and assaulted her. The State presented evidence of prior abuse, Perrault’s changing accounts and false alibi, physical evidence inconsistent with suicide, and statements to a jailhouse informant. The medical examiner considered suicide the most compelling explanation, but the jury rejected that theory. Perrault received life without parole for murder and a concurrent 12-month battery sentence. The Supreme Court of Georgia affirmed. It held that the jury could reject suicide as unreasonable and find guilt beyond a reasonable doubt, notwithstanding conflicts in the evidence. Perrault’s venue claim was not reviewable because he withdrew his change-of-venue motion before the trial court ruled; his ineffective-assistance theory about counsel’s withdrawal was raised too late, in his reply brief. His cumulative-error claim also failed because he did not adequately identify, locate, or show trial errors to aggregate. The court therefore found no basis for a new trial.

Opinion

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