Supreme Court of Georgia

Brown v. the State.

February 5, 2018810 S.E.2d 145

Summary

The court held that the evidence was sufficient to support Brown's malice-murder and aggravated-assault convictions, including rejection of his self-defense challenge. It nevertheless reversed because the trial court improperly admitted prior aggravated-assault convictions under the other-acts rule: accident and mistake were not at issue, the evidence had minimal probative value in light of the self-defense claim, and its prejudicial effect substantially outweighed its value. The error was not harmless because the evidence of guilt was not overwhelming and the record contained substantial evidence bearing on self-defense.