Jul. 1—A Glynn County man convicted of sexually assaulting and murdering a 6-year-old is back on death row following a decision by the Georgia Supreme Court that was released this week.
The state Supreme Court issued a ruling Thursday that reversed a 2022 decision to vacate the death sentence of David Edenfield and sent the case back for another habeas corpus hearing.
Habeas corpus is a fundamental right in the U.S. Constitution protecting against unlawful and indefinite imprisonment.
Edenfield was convicted in 2009 of molesting and murdering 6-year-old Christopher Michael Barrios Jr. in 2007 while Edenfield’s wife, Peggy Edenfield, watched. David Edenfield was sentenced to death following his conviction.
The couple’s son, George Edenfield, was also accused of murder and molestation in the case, but has been deemed unfit to stand trial due to developmental disabilities. He is being held at an in-patient state hospital operated by the Department of Behavioral Health and Developmental Disabilities.
David Edenfield filed a petition for a writ of habeas corpus in December 2014 and amended it in 2018 arguing that he was ineligible for the death penalty because he is intellectually disabled and that his attorney in his criminal trial was ineffective in presenting that disability to the court.
He also argued that the attorney who represented him in a 2013 appeal was ineffective. The Georgia Supreme Court in that appeal upheld David Edenfield’s conviction and sentence.
A Butts County court vacated the death sentence in August 2022 following a habeas corpus hearing in which Edenfield claimed ineffective counsel. That decision was then challenged by the warden at the Georgia Diagnostic and Classification State Prison, prompting the Supreme Court’s review and the opinion it released Thursday.
In the unanimous opinion written by Justice Charlie Bethel the court concluded that Edenfield’s trial attorney was not ineffective.
“[I]n the guilt/innocence phase, the jury would have been required to consider whether Edenfield had proven beyond a reasonable doubt that he was intellectually disabled under the statutory and clinical definitions of that condition,” Bethel wrote. “In view of the higher burden applicable here … we conclude that there is no reasonable probability that the evidence presented in the habeas court would have led Edenfield’s jury to find him guilty but intellectually disabled beyond a reasonable doubt.”
By rejecting most of Edenfield’s claims of ineffective counsel but not all of them, the case will be sent back to a habeas court to consider other specific ineffective-counsel claims, a summary of the opinion said. Those claims are that the habeas court initially omitted findings of mitigating evidence as to Edenfield’s alleged disability, including his impoverished upbringing, physical abuse he suffered, his son’s propensity for violence, his family’s difficulty in adjusting to an earlier move, and evidence related to his previous incest conviction, the case summary said.
David Edenfield is currently being held at the diagnostic state prison.
Peggy Edenfield was sentenced to life in prison for her part in the crime. The district attorney’s office agreed not to seek the death penalty against her after she agreed to testify against her husband and son. She is being held in Pulaski State Prison.
Georgia Attorney General Chris Carr, Deputy Attorney General Beth Burton, and Assistant Attorney Generals Paula Smith and Clint Malcolm argued the case on behalf of the prison warden.
Attorneys Anna Arceneaux of the Georgia Resource Center, and James F. Bogan III argued on behalf of Edenfield.