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Gilreath v. State

The trial court prevented the defendant from presenting a complete defense when it granted the State's motion in limine to exclude a witness's testimony, which would have raised a reasonable inference of the defendant's innocence.

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Appellant Christopher Gilreath was convicted of malice murder and associated crimes in connection with the beating death of two-year-old Joshua Pinckney, the son of his live-in-girlfriend, Miriam Pinckney. Gilreath now appeals, arguing, inter alia, that the evidence was insufficient and that he was prevented from presenting a complete defense. For the reasons that follow, we affirm in part and reverse in part.1

Viewed in the light most favorable to the jury’s verdicts, the evidence adduced at trial established as follows. Pinckney had two young children, Joshua and Maria, both of whom were adopted from Guatemala; Pinckney and her children were living with Gilreath at the time of Joshua’s death. Pinckney saw Joshua alive on the evening of Wednesday, February 11, 2009, and numerous witnesses indicated that neither child had any visible injuries during the period leading up to that day. On February 12, 2009, Pinckney left the children at home alone with Gilreath while she went to work. During the morning of February 12, Pinckney made numerous attempts to contact Gilreath by phone, but she was unable to reach him. Gilreath, apparently unhappy with having to care for the children, eventually contacted Pinckney to advise her that Joshua had a really bad diaper and that she needed to return home.

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