Chatman v. Brown

Melton, Justice.

In May 1999, a jury found Derrick Brown guilty of kidnapping with bodily injury, aggravated assault upon a person 65 years or older, robbery by force, and burglary in connection with the beating and robbing of Margaret Logan. Brown’s convictions were upheld on appeal. Brown v. State, 243 Ga. App. 430 (533 SE2d 453) (2000). In December 2008, Brown sought habeas relief based on this Court’s then-controlling decision in Garza v. State, 284 Ga. 696 (670 SE2d 73) (2008), which established new factors for assessing the asportation element as required for kidnapping.1 Brown also…