Sconyers v. State
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The case involves Charles Michael Sconyers who was convicted for malice murder and cruelty to children in the first degree, in relation to the death of 23-month-old Lincoln Davitte. The child died from blunt-force trauma to his skull. Evidence presented at trial showed that Sconyers and the child's mother, Chelsea Finch, lived together and that the child sustained a severe head injury while under Sconyers' sole care. Sconyers claimed the injury was due to a ground-level fall on the patio, but several medical experts testified that the injury was inconsistent with such a fall.
Sconyers was indicted for malice murder, two counts of felony murder, and one count each of aggravated assault and cruelty to children in the first degree. He was found guilty on all counts and sentenced to life in prison for malice murder and concurrent 20-year prison terms for aggravated assault and cruelty to children. The felony murder counts were vacated by operation of law. Sconyers filed a motion for a new trial, which was denied by the trial court. He then appealed to the Supreme Court of Georgia.
Sconyers raised four issues on appeal: the trial court's repeated allowance of evidence of previous injuries to the child without cautioning the jury that the parties agreed Sconyers did not cause those injuries; the jury instruction about “prior difficulties” between Sconyers and the child without limiting what evidence qualified as prior difficulties; the admission of hearsay statements allegedly made by Finch; and the prosecution's alleged improper impeachment of Finch. The Supreme Court of Georgia affirmed the trial court's decision, rejecting all of Sconyers' arguments.
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