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Lowe v. State

The reasonable hypothesis rule applies only when the evidence is entirely circumstantial.

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This appeal arises from appellant Antonia Lowe’s murder conviction relating to the death of Lula Bell Scott.1

1. Appellant contends the evidence is insufficient to uphold her conviction. The relevant inquiry on appeal challenging the sufficiency of the evidence is whether the evidence, viewed in a light most favorable to the verdict, would authorize a rational trier of fact to find appellant guilty beyond a reasonable doubt of the crimes for which she is charged. Jackson v. Virginia , 443 U.S. 307, 319 99 SC 2781, 61 LE2d 560 1979; Cutrer v. State , 287 Ga. 272, 274 695 SE2d 597 2010. The evidence introduced at trial showed that on November 4, 2006, the body of Lula Bell Scott was discovered by hunters in the woods of McDuffie County. Based on the state of the body’s decomposition, law enforcement determined the victim had been dead since at least the first week of September 2006. Clarice Billings, appellant, and Scott, who was Billings’s mother, all lived together. At trial, Billings testified she last saw the victim on September 1, 2006, when she and appellant went looking for Scott in Thomson, Georgia McDuffie County to urge her to return to their home in Hephzibah, Georgia Richmond County. When they could not persuade Scott to come back home, Billings and appellant went to a friend’s house. Appellant then offered to go look for and talk to Scott one more time. When appellant came back, she reported to Billings that she had hit a deer.

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