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Singletary v. State

The state failed to prove that the defendant engaged in a fight in a public place when the fight took place in a county jail.

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Douglas Williams Singletary appeals his conviction for affray, contending that the evidence was insufficient to support his conviction beyond a reasonable doubt because the State failed to prove that he engaged in a fight in a public place.1 For the reasons noted infra , we agree and reverse Singletary’s conviction. Viewing the evidence in the light most favorable to the jury’s verdict,2 the record shows that on January 4, 2010, Singletary was a prisoner in the Hall County Jail. Early that morning, Singletary and another inmate, Kevin Eccles, were clearing breakfast trays from a communal area in their cell pod when the two became engaged in a physical altercation. An officer assigned to the area became aware of the fight when he noticed the reactions of locked-up inmates, who were looking down into the communal area.

Several officers responded to the fray and commanded Singletary and Eccles to stop fighting. The two inmates, however, refused to cease their fisticuffs, and the officers eventually had to step in and separate them. For his part, Singletary resisted the officers’ efforts to restore order while unleashing a stream of obscenities at them; but he was ultimately subdued with a taser, handcuffs, and leg shackles. And while Eccles later characterized his altercation with Singletary as merely “a little tussle,” this unfortunate encounter left several puddles of blood on the floor.

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