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Joyner v. State

The trial court did not err in admitting a videotape showing the victim's bound and decomposed body where the evidence clearly established the defendant's participation in the crimes.

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Elizabeth Joyner was convicted by a jury of felony murder, armed robbery, and burglary, in connection with the death of William Wright.1 On appeal, Joyner asserts that the evidence was insufficient to support her convictions because she lacked the criminal intent necessary to commit the crimes, and that the trial court erred in admitting a videotape and photographs depicting the victim’s decomposing body. Finding no error, we affirm the convictions. But because Joyner was improperly sentenced for both felony murder and the underlying offense of armed robbery, we vacate the conviction and sentence for armed robbery. Elizabeth Joyner and her boyfriend, Gregory Baker, encountered Christopher Reid at a state park in Reidsville, Georgia. Baker and Reid had been acquaintances for several years. In Joyner’s presence, the two men discussed going to “hit a lick” or commit a robbery. They selected William Wright, a 71-year old bar proprietor, as the victim because they believed he would have money. According to Reid, Joyner was “right there” while the plan was being hatched, and she “knew everything that was going on.”2

Joyner drove Baker and Reid to Reid’s home, where Reid obtained a gun, and displayed the gun to her and to Baker. Joyner continued to drive the two to Baker’s home where Reid sawed off a shotgun and told the others that it was for use in the robbery. They wound up at Joyner’s home where they consumed alcohol and practiced shooting Reid’s gun.

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