## Facts

- Clyde Hufstetler was tried for the shooting death of his estranged wife, Nancy Hufstetler, occurring two days before their divorce was to become final.
- Hufstetler did not dispute that he shot and killed the victim but asserted justification, claiming he was a battered spouse who acted in self-defense.
- The State presented evidence that Hufstetler was the abuser, including prior assaults and threats against the victim.
- A State expert opined that the victim, not Hufstetler, fit the battered-spouse profile.
- The couple’s son witnessed the shooting and testified that Hufstetler acted out of jealousy and fled intending to kill a suspected paramour.
- Hufstetler fled the scene, evaded capture, and was arrested while still in possession of the firearm.

## Issues

1. Whether the evidence, viewed in the light most favorable to the verdict, was sufficient for a rational jury to find beyond a reasonable doubt that the homicide was not justified and that Hufstetler committed malice murder.
2. Whether the trial judge’s remark during voir dire of a defense battered-spouse expert about “how many syndromes we have now,” absent a contemporaneous objection, constituted reversible error under plain-error review.

## Decision

- The Supreme Court of Georgia affirmed the conviction and life sentence.
- The court held the evidence was sufficient for the jury to reject justification and find malice murder beyond a reasonable doubt.
- The court held the judge’s challenged remark, considered in context, did not disparage the defense and did not amount to plain error requiring reversal.

## Legal Principles

- Under the constitutional sufficiency standard, an appellate court asks whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt when viewing the evidence most favorably to the verdict.
- The jury may credit the State’s witnesses and disbelieve defense witnesses; appellate review does not reweigh credibility determinations.
- A justification/self-defense claim may be rejected where the State’s evidence permits a finding beyond a reasonable doubt that the defendant was not justified.
- Alleged judicial impropriety not objected to at trial is reviewed, if at all, for plain error; contextual clarification of expert testimony, without showing bias or ridicule, does not warrant reversal.

## Conclusion

The court affirmed Hufstetler’s malice-murder conviction and life sentence, concluding that the State’s evidence allowed the jury to find the killing unjustified beyond a reasonable doubt and that the trial judge’s isolated voir dire comment about “syndromes” did not constitute plain error.


Hufstetler v. State, 274 Ga. 343, 553 S.E.2d 801 (Ga. 2001)