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Price v. State

2023-05-31

Summary

Holding. The judgment is affirmed. The court affirmed the conviction for malice murder as supported by sufficient evidence and affirmed the trial court's denial of the motion to sever the cocaine possession charge from the homicide charges.

Trevis Lavell Price was convicted by jury of malice murder in the deaths of two men, along with additional charges including drug offenses. Price appealed on two grounds: first, that insufficient evidence supported his malice murder convictions, and second, that the trial court should have separated the cocaine possession charge from the homicide charges for a separate trial. Price argued that gaps in the evidence—such as the absence of body camera footage of the victim's identification, failure to interview the victim in the hospital, and an eyewitness's inability to identify him—created reasonable doubt. He also contended that trying the drug charge alongside the murders unfairly prejudiced the jury against him on the more serious offenses.

The court rejected both arguments. Regarding sufficiency of evidence, the court applied the standard that it must determine whether any reasonable jury could have found guilt beyond a reasonable doubt based on the evidence presented. The victim identified Price as the shooter while in severe pain shortly after being shot, phone records showed communications and a drug transaction negotiation between Price and the victim in the days before the shooting, and an eyewitness described Price's presence at the scene and his interactions with the victim. The court emphasized that it does not reweigh evidence or resolve conflicts in testimony—those functions belong to the jury. Regarding the severance question, the court found that the trial judge properly exercised discretion in keeping the charges together because all the offenses stemmed from Price's involvement in drug dealing, and the trial court found the facts straightforward enough for the jury to distinguish between the different charges.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Sufficiency of evidence for malice murder conviction based on victim identification and circumstantial evidence
  • Whether inconsistencies or gaps in evidence (missing body camera footage, lack of hospital interview) undermine conviction
  • Whether trial court abused discretion by denying motion to sever drug possession charge from homicide charges

Procedural posture

Price appealed his jury convictions for malice murder and other offenses to the Georgia Supreme Court, challenging the sufficiency of evidence and the denial of his motion to sever charges.

Authorities cited

Opinion

majority opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court

Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the

opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any

prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and

official text of the opinion.

In the Supreme Court of Georgia

Decided: May 31, 2023

S23A0063. PRICE v. THE STATE.

BETHEL, Justice.

A Dougherty County jury found Appellant Trevis Lavell Price

guilty of malice murder and other offenses in connection with the

deaths of L. C. Tumblin Jr. and Dexter Covin. 1 On appeal, Appellant

1The crimes occurred on October 13, 2016. On May 1, 2019, a Dougherty

County grand jury re-indicted Appellant for two counts of malice murder

(Counts 1 and 2), two counts of felony murder (Counts 3 and 4), two counts of

aggravated assault (Counts 5 and 6), four counts of possession of a firearm

during the commission of a felony (Counts 7 through 10), possession of cocaine

with intent to distribute (Count 11), and possession of a firearm by a convicted

felon (Count 12). At a jury trial held from May 20 to May 31, 2019, Appellant

was found guilty of all counts. The trial court sentenced Appellant to serve life

in prison on Counts 1 and 2; five years each on Counts 7, 8, and 9, to run

concurrently with each other and consecutively to Counts 1 and 2; a split

sentence of 20 years in prison and 20 years on probation on Count 11, to run

concurrently with Counts 7, 8, and 9 and consecutively to Counts 1 and 2; and

five years on Count 12, to run concurrently with Counts 7, 8, and 9. Counts 5,

6, and 10 were merged for sentencing. The trial court purported to merge

Counts 3 and 4 for sentencing, but those counts were vacated by operation of

law. See Malcolm v. State, 263 Ga. 369, 371-372 (4) (434 SE2d 579) (1993).

On July 1, 2019, Appellant filed a motion for new trial, which he

amended through new counsel on July 2, 2020. The trial court denied the

challenges the sufficiency of the evidence supporting his convictions

for malice murder and the trial court’s denial of his motion to sever

the charge for possession of cocaine with intent to distribute. We

affirm.

1. Viewed in the light most favorable to the jury’s verdicts, the

evidence presented at trial showed as follows. Around 1:30 a.m. on

the night of October 13, 2016, officers with the Albany Police

Department were dispatched to a residential address on a report of

a possible shooting. When officers arrived, they observed one man

lying in the front yard of the residence and another man lying on the

front porch, both of whom had been shot. The man in the front yard,

later identified as Covin, was non-responsive and not breathing. The

man on the front porch, later identified as Tumblin, was moving and

making noises; when asked by a responding officer who shot him,

Tumblin responded, “Travis Price.” The officers testified that

Tumblin “was very scared, his voice was shaky, and it was a little

motion, as amended, on July 26, 2022. On August 4, 2022, Appellant filed a

timely notice of appeal. The case was docketed to this Court’s term commencing

in December 2022 and submitted for a decision on the briefs.

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hard to understand him.” The officers further noted that Tumblin

“was kind of hysterical,” “seemed to be very faint,” “was talking in a

very light voice,” and “seemed to be in excruciating pain.”

Nevertheless, when the officers again asked Tumblin to identify the

shooter, Tumblin repeated, “Travis Price.” Officers later learned

that Tumblin and Appellant were cousins. Tumblin was transported

to the hospital, where, four days later, he succumbed to an infection

caused by his wounds. Covin suffered a gunshot to the head, as well

as to his arm and torso; he died as a result of his injuries.

After the shootings, eyewitness Fred Armstrong identified

himself to the police. According to Armstrong, Covin owed him

money for repairs Armstrong had made to Covin’s vehicle, and on

the night of the crimes, Covin asked Armstrong to meet him at the

address where the shootings occurred to pick up the money Covin

owed. When Armstrong arrived, he saw Covin’s car with Covin and

Covin’s wife inside; he also saw a black Toyota Camry parked behind

the residence facing the street with its headlights on. Armstrong

observed Covin exit his car and approach the Camry. At that point,

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two men exited the residence, and one called out, “Who is this behind

my house this time of night?” Appellant, 2 who had stepped out of the

Camry, responded, “It’s your cousin.” Appellant and Covin then got

into the Camry together. Covin exited the Camry within two

minutes and began walking back to his own car; before Covin could

reach his car, however, Appellant exited the Camry, walked up

behind Covin, and shot him. Appellant turned around and shot at

the men on the front porch, then at Covin’s wife, and then toward

Armstrong’s vehicle. Covin’s wife sped off, followed by Armstrong.

Based on Tumblin’s identification and the interview with

Armstrong, police identified Appellant as a suspect in the shootings

and, after learning that he had recently moved in with his parents,

obtained a search warrant for Appellant’s room at the residence.

Crack cocaine, marijuana, a scale, and razor blades were recovered

during the search. One officer testified that the cocaine, which had

been divided into individual bags, was packaged for distribution and

2 Armstrong was unable to identify Appellant as the shooter either when

police showed him a photo lineup or at trial.

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that the weight of the cocaine—approximately nine grams—was

“not a normal user amount” and was “consistent with somebody

possessing it with the intent to distribute it.” The officer also

testified that the brief interaction between Appellant and Covin in

the Camry before the shooting was “consistent with performing a

narcotics . . . transaction in the vehicle.”

Appellant thereafter turned himself in to police and asked to

speak with investigators. During the interview, 3 a video recording of

which was played for the jury at trial, Appellant admitted ownership

of the drugs found at his parents’ house but denied any involvement

in the shootings. Appellant further acknowledged that he used

several names, including Trevis Price and Travis Price. Appellant

also identified two cell phone numbers he used; police later

subpoenaed records associated with those phone numbers.

At trial, the State introduced phone records showing that, from

October 10 to October 13, several calls were placed between

3 After receiving the warnings required by Miranda v. Arizona, 384 U. S.

436 (86 SCt 1602, 16 LE2d 694) (1966), Appellant executed a written waiver of

rights.

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Appellant’s phone and a phone associated with Covin, including a

call from Covin’s phone to Appellant’s phone approximately 15

minutes before the shootings. The records also reflected a series of

text messages between Covin’s phone and Appellant’s phone in the

days leading up to the shootings, the last of which was sent less than

three hours before the crimes. In text messages exchanged the day

before the shooting, Covin and Appellant negotiated and arranged

for Appellant to purchase some “clean” from Covin at a price of

$1,100; a police officer testified that “clean” is a “drug term” for

“some really good cocaine.”

On appeal, Appellant asserts that the evidence was insufficient

to support his convictions for malice murder 4 because, he says,

“undisputed inconsistencies and open questions” undermined the

evidence against him. Specifically, Appellant complains about the

absence of police body camera footage showing Tumblin identifying

him as the shooter and faults the police for failing to interview

4 Appellant does not challenge the sufficiency of the evidence to support

his other convictions.

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Tumblin at the hospital before his death. Appellant further

highlights Armstrong’s inability to identify Appellant as the shooter.

Finally, Appellant suggests that law enforcement’s investigation of

the crimes was flawed because investigators failed to recover

Appellant’s phone and because they initially believed Appellant and

Covin’s drug transaction involved methamphetamine, rather than

cocaine. These arguments are unavailing.

When evaluating the sufficiency of evidence, we view the

evidence presented at trial in the light most favorable to the jury’s

verdicts and ask whether any rational trier of fact could have found

the defendant guilty beyond a reasonable doubt. See Jackson v.

Virginia, 443 U. S. 307, 319 (III) (B) (99 SCt 2781, 61 LE2d 560)

(1979). “Our review leaves to the jury the resolution of conflicts or

inconsistencies in the evidence, credibility of witnesses, and

reasonable inferences to be made from the evidence,” Yarn v. State,

305 Ga. 421, 423 (2) (826 SE2d 1) (2019), and “[w]e do not reweigh

the evidence,” Dobbins v. State, 309 Ga. 163, 165 (2) (844 SE2d 814)

(2020). “As long as there is some competent evidence, even though

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contradicted, to support each fact necessary to make out the State’s

case, the jury’s verdict will be upheld.” (Citation and punctuation

omitted.) Roberts v. State, 305 Ga. 257, 259 (2) (824 SE2d 326) (2019).

Appellant’s contention that purported inconsistencies in the

evidence compromised the sufficiency of the evidence is meritless.

Indeed, Appellant’s argument goes to the weight and credibility of

the evidence, and it is axiomatic that “[t]his Court does not reweigh

evidence or resolve conflicts in testimony.” (Citation and

punctuation omitted.) Williams v. State, 287 Ga. 199, 200 (695 SE2d

246) (2010). Those determinations are reserved to the jury. See

Yarn, 305 Ga. at 423 (2). Likewise, it is of no consequence that the

State did not introduce a video recording of Tumblin’s statement or

the testimony of additional witnesses identifying Appellant as the

shooter. See OCGA § 24-14-8 (“The testimony of a single witness is

generally sufficient to establish a fact.”); Plez v. State, 300 Ga. 505,

506 (1) (796 SE2d 704) (2017) (“Although the State is required to

prove its case with competent evidence, there is no requirement that

it prove its case with any particular sort of evidence.”). The evidence

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recounted above was more than sufficient to authorize a rational

jury to find Appellant guilty beyond a reasonable doubt of malice

murder of both Covin and Tumblin. See Jackson, 443 U. S. at 319

(III) (B).

2. In his second and final enumeration of error, Appellant

asserts that the trial court erred by refusing to sever Count 11—

possession of cocaine with intent to distribute—from the remaining

charges. We are not persuaded.

When offenses are joined in a single indictment,

a defendant has a right to severance where

the offenses are joined solely on the ground that they are

of the same or similar character because of the great risk

of prejudice from a joint disposition of unrelated charges.

However, where the joinder is based upon the same

conduct or on a series of acts connected together or

constituting parts of a single scheme or plan, severance

lies within the sound discretion of the trial judge since the

facts in each case are likely to be unique.

(Citation and punctuation omitted.) Lowe v. State, 314 Ga. 788, 791-792 (2) (a) (879 SE2d 492) (2022). “If severance is not mandatory, it

is nevertheless incumbent upon the trial court to determine whether

severance is necessary to achieve a fair determination of [the

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defendant’s] guilt or innocence as to each offense.” (Citation and

punctuation omitted.) Carson v. State, 308 Ga. 761, 765 (2) (a) (843

SE2d 421) (2020). This inquiry requires the trial court to consider

“whether, in view of the number of offenses charged and the

complexity of the evidence to be offered, the trier of fact will be able

to distinguish the evidence and apply the law intelligently as to each

offense.” (Citation and punctuation omitted.) Rodriguez v. State, 309

Ga. 542, 547 (2) (847 SE2d 303) (2020).

Here, the trial court found that severance was not mandatory

and, after determining that the facts of the case were “relatively

straightforward” and that the charges against Appellant all

stemmed from his involvement in drug dealing, denied Appellant’s

motion to sever. 5 On appeal, Appellant argues that severance was

5 Appellant begins this section of his brief by asserting that the trial court

erred by denying “several defense evidentiary motions,” but this section

includes factual and legal argument regarding only the denial of his motion to

sever. Appellant goes on to vaguely complain that the trial court denied “two

related defense motions concerning drug charges” against Appellant and “a

defense motion to admit evidence from two witnesses who interviewed victim

Tumblin in the hospital.” And he criticizes the trial court for “permitt[ing] the

[S]tate to introduce . . . evidence that . . . Tumblin identified Appellant as the shooter as a ‘dying declaration.’” Beyond these generalized complaints,

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warranted because, he says, the admission of evidence relevant to

Count 11, in conjunction with other unfavorable evidentiary rulings,

was “highly prejudicial” and “devastating” to his defense and

precluded “unbiased consideration by the jury on the more serious

offenses[.]” But Appellant points to “no evidence . . . that the

combined trial of the charges confused or misled the jury[.]”

(Citation and punctuation omitted.) Rodriguez, 309 Ga. at 547 (2).

And in light of evidence showing that the offenses arose from

Appellant’s drug-dealing activities, as well as the State’s theory that

the shootings resulted from a drug deal gone awry, we cannot say

that the trial court abused its discretion by denying Appellant’s

motion to sever. See Jackson v. State, 314 Ga. 82, 88 (2) (874 SE2d

95) (2022) (no abuse of discretion in denying motion to sever where

however, Appellant offers no cogent argument, citation of authority, or

citations to the record to support his bare assertion that these rulings were

erroneous. Thus, to the extent Appellant seeks to challenge these additional

rulings, he is not entitled to review of those claims. See Henderson v. State, 304 Ga. 733, 739 (4) (822 SE2d 228) (2018) (“It is not this Court’s job to cull the

record on behalf of Appellant to find alleged errors, as appellate judges are not

like pigs, hunting for truffles buried in briefs.” (citation and punctuation

omitted)); Roberson v. State, 300 Ga. 632, 636 (III) (797 SE2d 104) (2017) (“It

is well established that the burden is on the party alleging error to show it by

the record[.]” (citation and punctuation omitted)).

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evidence showed that crimes, which occurred over course of several

days, arose from appellant’s “continuing course of criminal violence

relating to his involvement in the drug trade”); Rodriguez, 309 Ga.

at 547-548 (2) (severance not warranted where “charged crimes all

related to [appellant’s] ongoing involvement in gang activity and

drug trafficking”); Carson, 308 Ga. at 765 (2) (a) (“Severance is

generally not warranted where the crimes charged occurred over the

same period of time and stem from a course of continuing conduct.”

(citation and punctuation omitted)).

Judgment affirmed. All the Justices concur.

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