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Joiner v. State

The defendant was in custody on an out-of-state felony charge when he escaped from the county jail.

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Following a bench trial, Jeffery Joiner was convicted on one count of felony escape.1 On appeal, he challenges the sufficiency of the evidence supporting his conviction, arguing that the trial court erred in finding him guilty of felony escape because he was not being held in legal custody on any felony charge at the time of his escape. For the reasons set forth below, we affirm. “On appeal from a criminal conviction, the evidence must be construed in a light most favorable to the verdict and Joiner no longer enjoys a presumption of innocence.” Punctuation omitted. Dennis v. State .2 In evaluating the sufficiency of the evidence to support a conviction, we do not weigh the evidence or determine witness credibility, but only determine whether a rational trier of fact could have found the defendant guilty of the charged offenses beyond a reasonable doubt. Jackson v. Virginia .3

So viewed, the evidence shows that on July 31, 2008, Joiner was arrested on charges of battery and aggravated battery as a result of a fight with his girlfriend and sister at an apartment in Dodge County, Georgia. Following Joiner’s arrest and confinement in the Dodge County jail, the sheriff’s office ran his name through the Georgia Crime Information Center “GCIC” network and discovered that the state of Florida had issued warrants for Joiner’s arrest on charges of aggravated battery and probation violation. Shortly after notifying Florida authorities that Joiner had been arrested, the sheriff’s office received copies of the Florida warrants via facsimile and U.S. mail. Joiner became aware of the Florida warrants when he was unable to post bond because of those charges. On August 16, 2008, Joiner escaped from the Dodge County jail. Three days later, authorities re-arrested him.

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