Snow v. State

── Snow v. State ── Court: Supreme Court of Georgia Date: May 19, 2026 Category: General NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion. In the Supreme Court of Georgia No. S26A0176 Christopher Dean Snow v. The State On Appeal from the Superior Court of Chatham County No. 2023CR650LHB Decided: May 19, 2026 MCMILLIAN, Justice. Appellant Christopher Snow was convicted of malice mur- der for stabbing his wife Casey Allen to death. 1 On appeal, Snow argues that the trial court erred in admitting testimony under the residual hearsay exception; denying Snow’s pretrial motion for a continuance; admitting a prior felony conviction into evidence un- 1 Allen died on the night of April 14, 2023. On June 14, 2023, a Hall County grand jury indicted Snow for malice murder (Count 1), felony murder predicated on aggravated assault, family violence (Count 2), and aggravated assault, family violence (Count 3). At a trial held in May 2024, the jury found Snow guilty of all counts. The trial court sentenced Snow to serve life in prison without the possibility of parole for Count 1, merged Count 3 into Count 1, and purported to also merge Count 2 into Count 1, although Count 2 was actually vacated by operation of law. See Washington v. State, 313 Ga. 771, 772–73 (2022). Snow filed a timely motion for new trial, which was amended by new counsel. Following a hearing, the trial court denied Snow’s motion for new trial, as amended, on June 30, 2025. Snow filed a timely notice of appeal on July 22, 2025, and the case was docketed to the term of this Court beginning in December 2025 and thereafter submitted for a decision on the briefs. der OCGA § 24-6-609 (“Rule 609”); refusing to vacate Snow’s con- viction because the indictment failed to allege Allen’s killing was unlawful; and overruling Snow’s objection to a statement made during the prosecutor’s closing argument. For the reasons that follow, we affirm. 1. The evidence presented at trial showed that Snow stabbed Allen to death in their apartment during the night of their first wedding anniversary. They began dating in 2021 and got married on April 14, 2022. About nine months later, Allen gave birth to the couple’s son. On the night of their first wedding anniversary, Snow’s aunt took care of their son at her home, so they could go out and celebrate their anniversary. At approximately 7:30 a.m. the next morning, Snow called his father and told him, “Dad, I can’t fix this. I really F’d up and did – you know, I’m really sorry. I’m really sorry …. We were there and she had a knife and I don’t know if she meant to but she might have nicked me. I’m not sure. I lost it …. She’s dead.” Snow’s father urged him to call the police, but instead, Snow went to his aunt’s house to pick up his son. Snow told his aunt that he and Allen got in an argument the night before about her driving home after drinking and that she did not come home, even though Snow and Allen had plans to go with Snow’s aunt to a family birthday party that day. Snow’s aunt went to the party without them, where Snow’s father told the au