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Mattei v. State

Supreme Court of Georgia

November 4, 2019



         Following a jury trial, Paul Joseph Mattei was found guilty of malice murder, aggravated assault, and various other offenses in connection with the shooting death of Angela Williams.[1] On appeal, Mattei contends that the evidence presented at trial was insufficient to support his convictions and that the trial court erred by admitting at trial character evidence in violation of OCGA § 24-4-404 (b). For the reasons below, we affirm.

         1. Viewed in the light most favorable to the verdicts, the evidence shows that, on the evening of June 30, 2011, Mattei shot Angela Williams twice in the chest and once in the arm, while Williams sat in her car in an isolated parking lot in Fairburn. Mattei then left the scene in his yellow truck, and Williams managed to drive herself a little over one half of a mile to a gas station, where police found her barely conscious. Despite being rushed to the hospital, she was pronounced dead upon arrival. The Fulton County medical examiner concluded that Williams's death was caused by a gunshot wound to the chest.

         Two months prior to the murder, Williams and Mattei had entered into a "marriage of convenience." The two did not move in together and kept their marriage largely a secret. Williams told a family member that the purpose of the marriage was for her to assist Mattei with a drug trafficking scheme involving a trip to the Bahamas. The same day that they married, Mattei added Williams as his spouse to his insurance policy. Under the terms of Mattei's family-rider policy, Mattei would collect $150, 000 upon his spouse's accidental death.

         Days before the Bahamas trip, Mattei told Williams the plan had changed, and they would be going to Florida instead of the Bahamas. On the night of her murder, Williams was scheduled to meet with Mattei to discuss their travel plans. Video surveillance recordings from surrounding businesses showed Williams's vehicle following Mattei's truck in the direction of the parking lot where she was shot, just ten minutes before the shooting. The recordings also showed his truck driving away from the scene shortly before rescue vehicles arrived.

         Police discovered that searches for how to obtain a death certificate had been made on Mattei's computer hours after Williams's shooting. The police also discovered that Mattei had made three inquiries between June 18, 2011 and July 4, 2011, checking on his life insurance policy. In a search of Mattei's vehicle after his arrest, police found paperwork that could be used to file a life insurance claim along with information on how to obtain a death certificate. On August 12, 2011, after obtaining the death certificate from Williams's daughter, Mattei notified the insurance company of Williams's death.

         At trial, Crystal Bridges, Mattei's former roommate, testified that shortly after she moved in with Mattei in December of 2009, he approached her about an insurance fraud scheme involving him running her over with his truck so they could file an insurance claim. A jailhouse informant, Marlon Avila, testified that in July of 2013, he and Mattei were housed in the same unit. During that time, Mattei told Avila that he had shot his wife three times with a .380 handgun. An analysis of the shell casings recovered from Williams's car showed she had been shot by a .380 handgun.

         Mattei attacks Avila's testimony regarding his confession as "uncorroborated and unreliable." But, issues of witness credibility are for the jury to decide. See Hayes v. State, 292 Ga. 506, 506 (739 S.E.2d 313) (2013). Based on the foregoing, we conclude that the evidence was sufficient to enable a rational trier of fact to conclude beyond a reasonable doubt that Mattei was guilty of the crimes for which he was convicted. See Jackson v. Virginia, 443 U.S. 307, 319 (III) (B) (99 S.Ct. 2781, 61 L.Ed.2d 560) (1979).

         2. Next, Mattei contends that the trial court erred by admitting into evidence Bridges's testimony about Mattei's 2009 conversation with her regarding a proposed insurance scheme. According to Mattei, this conversation was extrinsic evidence that had no logical relation or relevance to the charged murders. We disagree.

         Because Mattei's trial occurred after January 1, 2013, the admissibility of the extrinsic evidence in question in this case is governed by OCGA § 24-4-404 (b) ("Rule 404 (b)"). See Booth v. State, 301 Ga. 678 (3) (804 S.E.2d 104) (2017). And, a trial court's decision regarding the admissibility of such evidence is reviewed for abuse of discretion. See Smith v. State, 302 Ga. 717 (4) (808 S.E.2d 661) (2017). Rule 404 (b) provides in relevant part:

Evidence of other crimes, wrongs, or acts shall not be admissible to prove the character of a person in order to show action in conformity therewith. It may, however, be admissible for other purposes, including, but not limited to, proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.

         Other-acts evidence is admissible where:

(1) the evidence is relevant to an issue in the case other than the defendant's character, (2) the probative value is not substantially outweighed by undue prejudice, and (3) there is sufficient proof for a jury to find by a preponderance ...

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