Woodv.State
Tabitha Wood admitted killing her fiance and defended the case as self-defense, presenting evidence of his long history of abuse and expert testimony that she suffered from battered person syndrome. On appeal, she argued that the trial court should also have allowed testimony about the victim’s prior violence toward other women under Rule 405 and that excluding that evidence violated her right to present a complete defense. The Supreme Court of Georgia affirmed. It held that specific acts of a victim’s violence toward third parties were not admissible under Rule 405(b) because the victim’s violent character is not an essential element of self-defense. The court also concluded that Wood had not shown a clear constitutional violation from the trial court’s application of ordinary evidentiary rules.
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