Stephens v. State

Lajuante Stephens was convicted of malice murder, armed robbery, false imprisonment, and related crimes in the 2013 shooting death of Daniel Evers, who was ambushed on his family's rural property along with his father, Donald. Evidence at trial linked Stephens to the stolen getaway SUV, a gun tied to a prior shooting, and cell phone records placing him near the crime scene. On appeal, Stephens did not challenge the evidence against him. Instead he argued the trial judge wrongly excused a prospective juror, known as Juror 30, after the State presented a Florida felony record that seemed to match him, even though the birth year was off by one year and the listed height did not perfectly match. The Supreme Court of Georgia found the trial judge had discretion to resolve that conflicting information and did not abuse it by removing the juror.

A trial court does not abuse its discretion in striking a prospective juror for cause as an unrestored convicted felon when background evidence reasonably supports that finding, even if minor details like birth year or height contain small discrepancies, and any error in the strike is not grounds for reversal unless the defendant shows the resulting jury was not competent and unbiased.

The ruling confirms that Georgia trial judges have wide latitude to exclude prospective jurors suspected of being unrestored felons even when supporting records contain minor discrepancies, guiding how courts across the state screen jurors in future felony trials.

Affirmed

1. Georgia law (OCGA § 15-12-163 (b)(5)) allows either side in a felony trial to object to seating a juror who is a convicted felon whose civil rights have not been restored, giving the trial judge a basis to remove such a juror.
2. The State presented a Florida felony record matching Juror 30's name and most physical details; although the birth year was one year off and the listed height was disputed, the trial court weighed this evidence and found it sufficient to strike the juror for cause.
3. Appellate courts review a trial judge's decision to strike a juror for cause only for abuse of discretion, a standard that asks whether the judge's choice fell within a reasonable range, and give deference to how the judge resolved conflicting or equivocal juror testimony.
4. Applying that deferential standard, the Supreme Court of Georgia found no abuse of discretion in striking Juror 30 despite the minor discrepancies in the felony record.
5. The court further noted that even a mistaken removal of a juror for cause is not grounds for reversal unless the defendant shows the jury that actually decided the case was not competent and unbiased, and Stephens made no such showing.

• murder conviction
• jury selection
• juror strike for cause
• felon juror disqualification
• Clayton County