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Smart v. State

The trial court did not err in limiting evidence of the victim's homosexuality to the evidence which was relevant to defendant's claim of self defense.

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A jury in DeKalb County convicted Eddie Smart of malice murder, armed robbery, and related crimes for the killing of James Henry Williams, Jr.1 On appeal, Smart contends that the trial court erred by limiting the extent to which Smart could present evidence of the victim’s homosexuality. The trial court allowed Smart to present all relevant and admissible evidence and did not err by excluding irrelevant evidence that was intended merely to impugn the victim’s character. Therefore, we affirm. 1. The evidence at trial showed that Smart told police that he entered Williams’ apartment on December 4, 1999 to use the telephone, and that he killed Williams after Williams made unwanted sexual advances towards him. Smart stabbed Williams more than forty times in his head, neck, chest, arms, and back. The police found blood stains throughout the different rooms of the apartment. Police also found Williams’ briefcase, which appeared disordered and contained multiple empty bank deposit bags. The State presented evidence that Williams was known to carry money in his briefcase, and that Smart told an acquaintance that he killed Williams while robbing him to get money for his girlfriend.

After reviewing the evidence in a light most favorable to the jury’s verdict, we conclude that there was sufficient evidence for a rational trier of fact to find Smart guilty beyond a reasonable doubt of malice murder, felony murder, and armed robbery.2

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