## Facts

- Isaac Antonio Shellman was prosecuted in Chatham County for offenses connected to the July 13, 2016 shooting death of his wife, Shanelle Shellman, inside their home.
- Shanelle’s two minor children heard her scream “get off of me,” followed by a loud bump coming from a bedroom.
- The children went to the bedroom, saw Shanelle and Shellman on the floor, and called 911.
- Police arrived and found Shanelle and Shellman on the bedroom floor, each with a gunshot wound to the head; Shanelle was dead, Shellman was alive, and Shellman had a gun in his right hand.
- Officers searching the bedroom found a journal in a closet. The State attributed the journal to Shanelle.
- The journal described Shanelle’s feelings about her relationship with Shellman, including frequent fighting, jealousy, false accusations of infidelity, violence, unhappiness, and that she was “scared of what may happen.”
- At trial, Shanelle’s mother, best friend, and neighbor testified that the couple’s relationship was tumultuous; the best friend also testified Shellman was abusive.
- Over Shellman’s hearsay objection, the trial court admitted the journal entries under OCGA § 24-8-807 (Rule 807).
- The jury found Shellman guilty of malice murder and possession of a firearm by a convicted felon during the commission of a crime, and Shellman appealed.
- On appeal, Shellman argued (among other things) that the evidence did not exclude an alternative hypothesis that a police officer framed him.

## Issues

1. Was the evidence sufficient to support Shellman’s convictions for malice murder and possession of a firearm by a convicted felon during the commission of a crime, both under constitutional due process (Jackson v. Virginia) and under OCGA § 24-14-6’s circumstantial-evidence standard?
2. Did the trial court abuse its discretion by admitting Shanelle Shellman’s journal entries under OCGA § 24-8-807 (Rule 807), the residual hearsay exception?

## Decision

- The Supreme Court of Georgia affirmed Shellman’s convictions and sentence.
- The court held the evidence was sufficient under Jackson v. Virginia and OCGA § 24-14-6, and the jury was authorized to reject as unreasonable Shellman’s hypothesis that he was framed by a police officer.
- The court held the trial court did not abuse its discretion by admitting the victim’s journal under Rule 807 because the entries had sufficient guarantees of trustworthiness, were material to motive, and Shellman did not show the State could reasonably obtain other, more probative evidence of motive.

## Legal Principles

- In reviewing sufficiency under Jackson v. Virginia, the appellate court views the evidence in the light most favorable to the verdict and asks whether any rational trier of fact could have found the essential elements of the crimes beyond a reasonable doubt.
- Under OCGA § 24-14-6, when the State relies on circumstantial evidence, the evidence must exclude every reasonable hypothesis except guilt; whether an alternative hypothesis is reasonable is generally for the jury, and the verdict stands unless the jury’s rejection of the hypothesis is insupportable as a matter of law.
- OCGA § 24-8-807 (Rule 807) permits admission of hearsay not covered by other exceptions if the statement has equivalent guarantees of trustworthiness, is more probative on the point than other evidence the proponent can reasonably obtain, and admission serves the purposes of the evidence rules and the interests of justice.
- A victim’s private, contemporaneous writings about an abusive or volatile relationship may satisfy Rule 807 when the circumstances show reliability (including no apparent motive to fabricate) and the writings bear on the defendant’s motive.

## Conclusion

The Supreme Court of Georgia affirmed Shellman’s murder and firearm convictions, concluding that the trial evidence—viewed favorably to the verdict—allowed a rational jury to find guilt beyond a reasonable doubt and to reject as unreasonable the proposed framing theory, and that the victim’s journal was properly admitted under Rule 807 because it was reliable, probative of motive, and not reasonably replaceable with more probative evidence.


Shellman v. State, 897 S.E.2d 355 (2024)