Schell v. Georgia
Annotate this CaseAppellant Eugenia Schell challenged her 2016 convictions for malice murder and other crimes in connection with the death of her mother, Willie Jo Vaughn. Appellant had a demonstrated history of abuse and violence towards her mother. This pattern of behavior led to a permanent protective order being issued against Appellant on February 9, 2011. Sometime later, Vaughn invited Appellant to live with her at her home. In October 2014, however, Vaughn initiated eviction proceedings against Appellant. Vaughn went to stay with her youngest daughter, and Appellant was given a timeframe to vacate Vaughn’s home. Vaughn had the locks changed and a spare key for the new locks hidden somewhere outside the house by her grandson. In March 2015, people accustomed to seeing or hearing from Vaughn did not. Vaughn did not report to work or to services at the church that weekend. Neighbors, who had a good view of her home and regularly interacted with her, did not see Vaughn’s car in her driveway after March 26. On that date, Vaughn was seen in the backseat of her own car, driven by Appellant. On April 3, Vaughn’s vehicle was found submerged at the bottom of a boat ramp at Upper County Landing in Wayne County, Georgia. Vaughn was discovered in the back seat, a plastic bag near her head, and a white, vinyl-type material was found draped over her body. Large rocks taken from the banks of the boat ramp had been placed on the trunk of the vehicle to keep it from floating. In her sole enumeration of error, Appellant challenges the sufficiency of the evidence to support her convictions. Specifically, Appellant argued that evidence of her mere presence with Vaughn on March 26, 2015, did not prove her involvement in the murder. Appellant also argued there was no evidence that Vaughn was prevented from leaving or was taken from one location to another without her permission to support the kidnapping conviction. The Georgia Supreme Court found the evidence sufficient to support Appellant's conviction and affirmed the trial court's judgment.
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