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McKnight v. State - 283 Ga. 56, 656 S.E.2d 830 (2008)


Crawford v. Washington relates to the testimonial hearsay of a witness who is unavailable for cross-examination at trial. 


Defendant McKnight was convicted in a Fulton County trial court for murder, felony murder, aggravated assault, and armed robbery of one victim (Urban), and the murder, felony murder, aggravated assault, burglary, and armed robbery of another victim (Horning) after a bifurcated trial. Appealing from the convictions, McKnight challenged both verdicts, contending, among other things, that the evidence was insufficient and that improper evidentiary rulings were made in both trials. In Urban's trial, McKnight asserted that the trial court erred by admitting certain prior inconsistent statements made by a witness with regard to seeing McKnight with a gun as both impeachment and substantive evidence.


Were the convictions proper?




The court affirmed both of McKnight's convictions. As to Urban's murder, the court found no error as the witness was presented with her prior contradictory statement and was allowed to fully review it after being reminded of the time, place, person, and circumstance of the statement. After that review, the witness testified that she was both familiar with the statement and that the statement was fair and accurate. According to the Court, under those circumstances, an adequate foundation was laid for the statement to be used as impeachment evidence, and, since the witness was available at trial for cross-examination, the statement was also properly admitted as substantive evidence for the jury's consideration. As to the Horning murder, the court found the evidence was sufficient to support the conviction based on an eyewitness seeing McKnight fleeing, as well as the testimony of others.

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