The Georgia Supreme Court reversed the malice murder conviction of Jalen Shakur Biggs on Monday, ruling that the trial court abused its discretion by excluding crucial evidence about the victim's prior violent behavior. Biggs had been serving life in prison without the possibility of parole for the February 2021 shooting death of Keith Basham in Haralson County.
In the opinion authored by Justice Ellington and decided Feb. 3, 2026, the high court found that the trial court erred by excluding evidence that Basham had previously assaulted the mother of Biggs's fiancée, April Oubre. The court also determined that the trial judge improperly refused to give the jury an instruction on voluntary manslaughter as a lesser included offense.
The case stems from events on Feb. 22, 2021, when Biggs and his fiancée Miranda Bell traveled from South Carolina to Basham's house in Haralson County. According to trial evidence, they went to pick up Oubre, who was Bell's mother and Basham's girlfriend at the time, along with her belongings. During an argument between Oubre, Bell, and Biggs with Basham, the fatal shooting occurred.
A Haralson County grand jury indicted Biggs on March 23, 2021, on charges of malice murder, felony murder, and aggravated assault. Following a jury trial that concluded on Nov. 2, 2023, Biggs was found guilty on all counts. The trial court sentenced him on Jan. 8, 2024, to life in prison without parole for malice murder. The felony murder count was vacated by operation of law, and the aggravated assault count was merged into the malice murder conviction for sentencing purposes.
Biggs filed a timely motion for new trial, which he amended on Jan. 31, 2025. The trial court denied the amended motion on May 23, 2025, prompting Biggs to file his appeal to the Georgia Supreme Court.
The central issue on appeal was whether the trial court properly excluded evidence of Basham's prior assault on Oubre under Georgia's Rule 403, codified as OCGA § 24-4-403. This rule allows courts to exclude relevant evidence if its probative value is substantially outweighed by unfair prejudice, confusion of issues, or misleading the jury.
Biggs argued that evidence of Basham's prior violent act toward Oubre was relevant to his claim of self-defense and should have been admitted to provide context for the circumstances leading to the shooting. The defense contended that this evidence was crucial to understanding the dynamics of the confrontation and Biggs's state of mind during the incident.
The prosecution had argued that the prior assault evidence was more prejudicial than probative and should be excluded to prevent the jury from being unfairly influenced against the victim. Trial courts are typically given significant discretion in making such evidentiary rulings under Rule 403.
However, the Georgia Supreme Court found that the trial court abused its discretion in this case. The court determined that the probative value of the evidence regarding Basham's prior violent behavior substantially outweighed any potential for unfair prejudice, particularly given its relevance to the defendant's theory of self-defense.
The high court also addressed Biggs's contention that the trial court erred in refusing to instruct the jury on voluntary manslaughter as a lesser included offense. Under Georgia law, voluntary manslaughter occurs when a person causes the death of another human being under circumstances that would otherwise be murder, but which are committed solely as the result of a sudden, violent, and irresistible passion resulting from serious provocation.
The Supreme Court's decision to vacate the trial court's order denying Biggs's motion for new trial and remand the case with direction suggests that the excluded evidence could have materially affected the jury's verdict. The court's ruling indicates that had the jury been presented with evidence of Basham's prior assault on Oubre, it might have reached a different conclusion about Biggs's culpability.
The case highlights the critical importance of evidentiary rulings in criminal trials and the careful balance courts must strike between admitting relevant evidence and protecting against unfair prejudice. When evidence of a victim's prior violent acts is relevant to a defendant's claim of self-defense, courts must carefully weigh whether its probative value substantially outweighs the risk of unfair prejudice.
This reversal means that Biggs will likely face a new trial, where the previously excluded evidence about Basham's assault on Oubre may be presented to the jury. The prosecution will need to decide whether to retry the case or potentially negotiate a plea agreement.
The Georgia Supreme Court's decision serves as a reminder that evidentiary rulings, particularly those involving Rule 403 exclusions, are subject to appellate review for abuse of discretion. When trial courts exclude evidence that is central to a defendant's theory of the case, such rulings face heightened scrutiny on appeal.
The case was docketed to the August 2025 term and decided on the briefs without oral arguments.