Norwood v. State: Reaffirming No-Knowledge Requirement for First-Degree Child Cruelty and Clarifying “Thirteenth Juror” Review in Georgia

I. Introduction

In Norwood v. State, S25A1383 (Ga. Dec. 9, 2025), the Supreme Court of Georgia affirmed the convictions and sentences of Deonte Norwood for the malice murder of his wife, Crystal Powell, and five counts of first-degree cruelty to children arising from the psychological trauma inflicted on five children who witnessed or experienced the immediate aftermath of Powell’s fatal stabbing.

The opinion addresses two central legal issues:

Whether the evidence was constitutionally sufficient under Jackson v. Virginia to sustain five counts of first-degree cruelty to children under OCGA § 16-5-70(b), particularly where the defendant claimed he lacked actual knowledge that children were present during the crime.
Whether the trial court failed to properly exercise its “thirteenth juror” discretion under OCGA §§ 5-5-20 and 5-5-21 when denying Norwood’s motion for a new trial on the general grounds.

The Court’s decision does not create wholly new doctrine, but it significantly reinforces and applies two important Georgia principles:

First-degree cruelty to children based on “excessive mental pain” does not require proof that the defendant knew children were present when he committed the malicious act. This follows and strengthens the Court’s earlier decision in Oliphant v. State.
Appellate review of a denial of a new trial on the “general grounds” remains extremely limited. Where a trial court correctly states the general-grounds standard and acknowledges its discretion, the appellate courts will presume it properly exercised its role as “thirteenth juror.”

II. Factual and Procedural Background

A. The Relationship and Escalating Conflict

Norwood and Crystal Powell married in 2020 and had a child, N.N., in 2021. Powell had three other children from a prior marriage: K.H. (8), O.H. (6), and B.H. (3). Powell also frequently cared for her cousin Zachary Hilty’s sons, M.H. (11) and W.H. (8). All five children had previously spent time in the home Powell shared with Norwood.

The marriage deteriorated. In June 2021, Powell sought a temporary protective order, and her sister testified that Norwood had put a gun to Powell’s head while she held their infant, N.N. After the separation, a bitter dispute over child support followed.

Text messages extracted from Norwood’s phone show:

On April 12, 2022, the parties arranged for Norwood to have N.N. for Easter, but the exchange quickly devolved into accusations about child support, with Norwood accusing Powell of “dangling” N.N. “like a carrot.”
On April 15, 2022, the communication again turned hostile over child support—Norwood’s texts stated that Powell did not “need” support and that she lied about how much he paid.

Powell’s sister testified that on that same day, Powell said she was about to serve Norwood with “child support papers” and predicted that he would “flip his s**t” when served.

B. The Night of the Killing

On April 16, 2022, the five children—K.H., O.H., B.H., M.H., and W.H.—spent the night at Powell’s home in Walton County. That evening’s text exchange between Powell’s phone and Norwood’s phone again reflected tension:

At 8:15 p.m., Norwood’s phone texted that “work ran late” and he would pick up N.N. the next morning. Powell’s phone responded that she would not “get[ ] up that early” because she “ha[d] all the kids.”
A dispute arose over the pickup location. Powell’s phone indicated she was in Monroe and reminded Norwood that she had driven to Monticello for months so he could see N.N. and that she was “done” doing that.
Powell’s phone provided her Monroe address and warned, “cops live next door so I wouldn’t try anything stupid.” Norwood’s phone responded, “Idgaf” (“I don’t give a f**k”) and “they live everywhere.”
At 9:15 p.m., Norwood’s phone texted, “here.”

C. The Attack and Its Immediate Aftermath

The children’s forensic interviews—admitted and played for the jury—described the attack and its impact:

M.H. and W.H. said they saw Norwood stabbing Powell, observing from a window; W.H. viewed it from downstairs through blinds.
O.H. described seeing Norwood retrieve his “weapon.”
K.H. reported seeing Norwood throw Powell’s body inside the house.
At some point, four of the children (M.H., W.H., K.H., and O.H.) ran upstairs, locked themselves in a room, and hid. O.H. said they ran because they were “scared” and because Norwood “was coming inside to check again if there was any kids.”
M.H. called both Hilty and 911. The 911 recording—played for the jury—captured M.H.’s pleas for help and his obvious fear. W.H. later described feeling scared and hiding in fear during the call.

Police arrived, saw the children’s faces through a window, and then discovered Powell’s body in a pool of blood. As the children exited the residence:

They all saw Powell’s body. M.H. had to step over it; B.H. stepped in his mother’s blood and later said that made him “sad.”
K.H. said his heart “raced” when he saw his mother lying on the floor.
O.H. likewise saw Powell’s body covered in blood.

The medical examiner testified that Powell sustained 14 stab wounds and other injuries, and that the wounds had no features suggesting self-infliction.

D. Norwood’s Statements and Trial Testimony

Norwood was arrested the next day at his father’s home. After receiving a Miranda warning, he was interviewed on video. The video was played for the jury. Norwood told investigators:

He “snapped” and stabbed Powell after placing N.N. in the car.
He denied seeing any children during the attack but admitted that he heard them, looked toward the door, recognized that “somebody must be there,” and left.

At trial, however, Norwood recanted. He claimed:

Powell, allegedly suffering from mental health issues, stabbed herself in his presence.
After she opened the door and he “heard kids in the house,” he closed the door and laid her down so the children “can’t see this right now.”
He briefly left with N.N., then returned, but Powell was no longer where he left her. He speculated that she might have walked away or perhaps one of the children helped her, though he did not know.
He insisted he thought Powell did not have custody of her children and believed she referred to a boyfriend’s child when she said she had “the kids” that night.

The children testified at trial consistently with their interviews:

M.H. and W.H. again stated they saw Norwood stabbing Powell.
O.H. and K.H. identified Norwood in court as the assailant.
B.H., the youngest, could not make a positive in-court identification.

Hilty testified that the children were “terrified” on the night of the murder and that afterward his sons woke up in the night screaming because they believed Norwood might come through a window to repeat the attack.

E. Procedural History

A Walton County grand jury indicted Norwood on ten counts, including:

Malice murder (Count 1);
Two felony-murder counts (Counts 2 and 3);
Family violence aggravated assault and family violence battery (Counts 4 and 5);
Five counts of first-degree cruelty to children, one count per child (Counts 6–10).

After a February 2024 jury trial, Norwood was convicted on all counts. The court imposed:

Life without parole for malice murder (Count 1);
Felony murder counts vacated by operation of law; Counts 4 and 5 merged into Count 1;
20 years’ imprisonment for each cruelty-to-children count (Counts 6–10), to run consecutively.

Norwood moved for a new trial and later amended the motion through new counsel. The motion was denied following a hearing, and Norwood appealed, raising:

A federal due process challenge to the sufficiency of the evidence on the five child cruelty counts.
A claim that the trial court failed to properly exercise its “thirteenth juror” role in denying his general-grounds motion under OCGA §§ 5-5-20 and 5-5-21.

III. Summary of the Supreme Court’s Decision

The Supreme Court of Georgia unanimously affirmed.

A. Sufficiency of the Evidence – First-Degree Cruelty to Children

Applying Jackson v. Virginia and Georgia precedent, the Court held that a rational jury could find Norwood guilty beyond a reasonable doubt of five counts of first-degree cruelty to children under OCGA § 16-5-70(b). The Court concluded:

Norwood unquestionably committed an act “with malice” (the stabbing of Powell, as reflected in the malice murder conviction).
That act caused each child “cruel or excessive mental pain” as shown by their fear, terror during the incident, physiological responses (e.g., racing heart), and ongoing trauma (e.g., nightmares).
OCGA § 16-5-70(b) does not require that the defendant have specific awareness of a child’s presence at the time of the malicious act; that is, there is no “knowledge-of-presence” element. The Court explicitly relied on and quoted Oliphant v. State.

B. General Grounds and the “Thirteenth Juror” Role

On the general grounds, the Court reaffirmed that:

Under OCGA §§ 5-5-20 and 5-5-21, a trial court may grant a new trial if the verdict is “contrary to evidence and the principles of justice and equity” or “decidedly and strongly against the weight of the evidence.”
When these grounds are invoked, the trial court serves as a “thirteenth juror” and may weigh evidence, assess witness credibility, and decide whether the verdict is against the weight of the evidence.
On appeal, however, the reviewing court does not reweigh the evidence. It merely checks whether the trial court understood and exercised its discretion.

In Norwood’s case:

The trial court correctly stated the legal standard under §§ 5-5-20 and 5-5-21 and acknowledged its discretion.
There was no “affirmative evidence” that the court misunderstood or failed to exercise its “thirteenth juror” role.
Accordingly, under Ward v. State and Anderson v. State, the Supreme Court presumed the trial court properly exercised its discretion and affirmed the denial of a new trial.

IV. Detailed Legal Analysis

A. First-Degree Cruelty to Children: Statutory Elements and Sufficiency

1. Governing Law: OCGA § 16-5-70(b) and Jackson v. Virginia

OCGA § 16-5-70(b) defines first-degree cruelty to children:

“Any person commits the offense of cruelty to children in the first degree when such person maliciously causes a child under the age of 18 cruel or excessive physical or mental pain.”

Under Jackson v. Virginia, 442 U.S. 307, 319 (1979), a conviction satisfies federal due process if, viewing the evidence in the light most favorable to the verdict, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. Georgia cases such as Henderson v. State, 317 Ga. 66 (2023), and Perkins v. State, 313 Ga. 885 (2022), reiterate that:

The reviewing court does not reweigh evidence or assess credibility;
Conflicts in evidence and questions of witness credibility are for the jury;
All reasonable inferences are drawn in favor of the verdict.

In Oliphant v. State, 295 Ga. 597 (2014), the Court construed § 16-5-70(b), holding that the statute requires only:

“that the defendant commit an act with malice and, in doing so, cause a child the requisite pain.”

Critically, Oliphant held that the statute does not require that the defendant be “specifically aware” that a child is present during the malicious act.

2. Malice Element in Norwood

Norwood’s malice was effectively established by his unchallenged malice murder conviction:

The Supreme Court noted that Norwood did not appeal the malice murder conviction.
As in Oliphant, where an accomplice to malice murder was held to have committed a “malicious act” for child cruelty purposes, Norwood’s murder conviction satisfied the malice component of § 16-5-70(b).

In other words, the act of stabbing Powell fourteen times was a paradigmatic “malicious” act under Georgia law, and no additional separate showing of malice specifically directed at the children was required.

3. “Cruel or Excessive Mental Pain”: Evidence Supporting Each Count

The central sufficiency question was whether Norwood’s malicious act caused “cruel or excessive mental pain” to each child. The Court relied on:

Hilty’s testimony that the children were “terrified” that night and that M.H. and W.H. later awoke screaming, believing Norwood might enter through a window and repeat the attack.
M.H.’s panicked 911 call, during which he pleaded for help and conveyed intense fear.
W.H.’s description of being scared and hiding while M.H. called 911.
O.H.’s report that they ran and hid because they were scared and believed Norwood was coming back into the house to check whether any children were present.
K.H.’s description of his heart racing at the sight of his mother’s body on the floor.
B.H.’s statement that stepping in his mother’s blood and seeing the scene made him “sad.”

In Oliphant, the Court held that children’s testimony about their “fright and angst” during and immediately after a shooting was sufficient to establish “excessive mental pain.” Norwood follows that approach: children’s fear during the crime, their immediate traumatic exposure to their mother’s body, and their ongoing psychological symptoms together meet the statutory requirement.

4. Rejection of a Knowledge Requirement: No “Legal Impossibility”

Norwood argued that, without direct proof he knew the five children were present, it was “legally impossible” to find that he “maliciously” caused them mental pain. The Court rejected this argument both as a matter of statutory interpretation and as inconsistent with Oliphant.

The Court reiterated Oliphant’s core holding:

“The statute does not require evidence that [a] defendant ha[ve] any specific awareness of a child’s presence when committing the act [of malice] in question.”

The statutory structure is important:

Malicious act: The defendant must commit some act with malice (here, the fatal stabbing).
Causation of pain: That act must, in fact, cause a child cruel or excessive mental or physical pain.

The statute does not say the defendant must:

Intend that the child suffer;
Directly target the child;
Even know the child is present, so long as the child is under 18 and actually suffers the requisite pain.

Under this framework, Norwood’s “legal impossibility” argument fails. Whether he believed the children were there is not an element of the offense; once he committed a malicious act that in fact produced extreme psychological trauma in minors, the statutory elements were satisfied.

Moreover, even if awareness were relevant evidentially, there was evidence from which a jury could infer Norwood’s knowledge:

Powell’s text: “I have all the kids.”
Norwood’s dismissive response—followed by his “Idgaf” message when warned that police lived next door—could be read as indifference to the risk.
In his police interview, Norwood admitted that he heard the children and looked toward the door, concluding that “somebody must be there.”

The Court, however, did not need to lean on these inferences because, under Oliphant, knowledge of the children’s presence is not a required element.

5. Application of Jackson: Deference to the Jury

Applying the Jackson standard as articulated in Henderson and Perkins, the Court emphasized:

It must view the evidence “in the light most favorable to the verdict” and give the State the benefit of all reasonable inferences.
It may not resolve conflicts in favor of the defendant or reassess credibility; those are the jury’s domain.

Under that deferential lens, Norwood’s recantation and alternate story about Powell’s alleged self-harm could not defeat the jury’s choice to believe:

Multiple child witnesses who saw him stab Powell;
His earlier confession that he “snapped” and stabbed her;
The physical evidence, including the multi-tool knife at the scene and the autopsy results indicating homicide.

The Court therefore held the evidence constitutionally sufficient to support all five first-degree child cruelty convictions.

B. General Grounds and the “Thirteenth Juror” Standard

1. Statutory Framework: OCGA §§ 5-5-20 and 5-5-21

Georgia law provides two related “general grounds” for a new trial:

OCGA § 5-5-20: A new trial may be granted where the verdict is “contrary to evidence and the principles of justice and equity.”
OCGA § 5-5-21: A new trial may also be granted where the verdict is “decidedly and strongly against the weight of the evidence.”

When a defendant invokes these provisions, the trial judge assumes a distinct role, articulated in Thompson v. State, 318 Ga. 760 (2024):

The trial court exercises broad discretion to sit as the “thirteenth juror” and may consider conflicts in the evidence, credibility of witnesses, and the weight of the evidence.

This “thirteenth juror” role is different from a Jackson-style sufficiency review:

Under Jackson, the question is whether any rational jury could convict, viewing evidence in the State’s favor.
Under the general grounds, the trial judge may independently weigh credibility and may grant a new trial even if the evidence is legally sufficient.

2. Appellate Review of General-Grounds Rulings

The Supreme Court’s precedents strictly limit appellate review:

In Ward v. State, 316 Ga. 295 (2023), the Court held it does not act as a thirteenth juror and does not independently weigh the evidence in reviewing a general-grounds ruling.
Instead, the appellate court asks only whether the trial court understood and actually exercised its discretion under §§ 5-5-20 and 5-5-21.
The Court “presume[s], in the absence of affirmative evidence to the contrary, that the trial court did properly exercise such discretion.”
In State v. Denson, 306 Ga. 795 (2019), the Court explained that trial courts are not required to make detailed written findings about which evidence or credibility determinations they considered, as long as the record shows they applied the correct standard.
Anderson v. State, 319 Ga. 56 (2024), reiterates that, absent “affirmative evidence” that a trial court failed to exercise its discretion, the appellate courts must presume proper exercise.

3. Application in Norwood

Norwood argued that the trial court—denying his motion for a new trial on the general grounds—had failed to meaningfully weigh the evidence and consider credibility, as required by the “thirteenth juror” role.

The Supreme Court rejected this argument for two reasons:

The trial court recited the correct legal standard. The order set out the language of OCGA §§ 5-5-20 and 5-5-21 and expressly recognized that the trial court had discretion to grant a new trial if the verdict was contrary to justice or strongly against the weight of the evidence.
There was no affirmative evidence that the court failed to exercise that discretion. Norwood could not point to any statement or action by the trial court suggesting it believed it was bound by the jury’s verdict, or that it applied only a sufficiency-of-the-evidence standard.

Under Ward and Anderson, the Supreme Court was therefore required to presume that the trial court properly weighed the evidence and exercised its “thirteenth juror” discretion. The denial of a new trial on the general grounds was affirmed.

C. Precedents Cited and Their Influence

1. Jackson v. Virginia, 442 U.S. 307 (1979)

Jackson established the federal constitutional minimum for sufficiency of the evidence:

A conviction satisfies due process if, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements beyond a reasonable doubt.

Georgia consistently applies this standard, as in Henderson and Perkins. In Norwood, the Court uses Jackson as the yardstick for evaluating the child cruelty convictions.

2. Oliphant v. State, 295 Ga. 597 (2014)

Oliphant is the cornerstone precedent for this decision. It held:

First-degree cruelty to children requires only that the defendant commit an act with malice and cause the child cruel or excessive mental or physical pain.
There is no requirement that the defendant know the child is present or specifically intend the child’s suffering.
Children’s testimony about their fear and distress during and after a violent event can suffice to establish “excessive mental pain.”

Norwood faithfully applies and reiterates these principles, particularly in rejecting Norwood’s claimed “legal impossibility” and in holding that the children’s fear, anguish, and ongoing trauma met the statutory standard.

3. Thompson, Ward, Denson, and Anderson – The General Grounds Line

Collectively, Thompson v. State, Ward v. State, State v. Denson, and Anderson v. State define modern Georgia doctrine on the general grounds:

Thompson: confirms that the trial court acts as “thirteenth juror” and must consider weight of the evidence and credibility when deciding a general-grounds motion.
Ward: restricts appellate review to checking that the trial court understood and exercised its discretion; requires presumption of proper exercise absent contrary evidence.
Denson: clarifies that the trial court need not make formal findings about how it weighed each piece of evidence, as long as it applies the correct standard and recognizes its discretion.
Anderson: reinforces that, without “affirmative evidence to the contrary,” appellate courts will not infer that a trial court failed to exercise its discretion.

Norwood follows this line closely, applying their principles to uphold the denial of Norwood’s motion for a new trial.

4. Miranda and Jenkins v. State

The opinion briefly notes that Norwood received Miranda warnings and cites Jenkins v. State, 317 Ga. 585 (2023), which itself cites Miranda v. Arizona, 384 U.S. 436 (1966). The admissibility of Norwood’s statements was not contested on appeal; the references simply confirm procedural regularity in obtaining his confession.

V. Clarifying Complex Legal Concepts

A. “Malice” in This Context

In Georgia criminal law, “malice” does not always mean hatred or spite in the everyday sense. It generally refers to:

An intent to kill or cause serious bodily harm without legal justification; or
A “depraved” or “abandoned and malignant heart” (an extreme disregard for human life).

For child cruelty under OCGA § 16-5-70(b), the “malicious act” can be any such act—here, the deliberate stabbing of Powell. Once that malicious act is established, the statute focuses on its effects on a child (the pain it causes), not on whether the defendant specifically intended to harm the child.

B. “Excessive Mental Pain” vs. Ordinary Distress

Many crimes may cause children sadness or anxiety, but first-degree cruelty to children requires “cruel or excessive” mental pain. Courts look for:

Acute fear or terror during a violent event;
Direct exposure to severe trauma (such as witnessing a parent’s murder or its aftermath);
Ongoing serious psychological symptoms (nightmares, fear of recurrence, severe anxiety).

In Norwood, the combination of:

Witnessing the stabbing;
Hiding in fear while the assailant searched for children;
Seeing their mother’s body in a pool of blood;
Later waking up screaming in fear that Norwood would return;

comfortably meets the statutory threshold, especially in light of Oliphant’s recognition that “fright and angst” during and immediately after a shooting were enough.

C. Distinguishing Constitutional Sufficiency from the General Grounds

Constitutional sufficiency (Jackson v. Virginia):

Focus: Could any rational jury have convicted, assuming the jury believed the State’s evidence?
Standard of review: Evidence viewed in light most favorable to the State; appellate courts do not reweigh evidence or assess credibility.
Source: U.S. Constitution’s Due Process Clause.

General grounds (OCGA §§ 5-5-20, 5-5-21):

Focus: Is the verdict contrary to the justice of the case or strongly against the weight of the evidence, even if legally sufficient?
Role of trial court: May reweigh evidence, evaluate credibility, and sit as “thirteenth juror.”
Source: Georgia statutes; provides a state-law basis to grant a new trial beyond constitutional requirements.
Appellate review: Extremely deferential; appellate courts only check that trial courts recognized and exercised their discretion.

In Norwood, the Court separately addressed both:

It upheld the child cruelty convictions as constitutionally sufficient.
It then held that the trial court properly exercised its general-grounds discretion, so its refusal to grant a new trial stands.

D. The “Thirteenth Juror” Concept

The phrase “thirteenth juror” captures the idea that, when ruling on a motion for new trial on the general grounds, the trial judge:

May independently assess whether the jury’s verdict is supported by the weight of the evidence;
Is not required to defer to the jury’s view of credibility;
Can grant a new trial even where the evidence meets the Jackson sufficiency threshold.

However, this powerful discretion belongs only to the trial court. Appellate courts in Georgia cannot take on the “thirteenth juror” role; they only verify that the trial court understood it had that power and used it.

VI. Broader Impact and Future Implications

A. Child Cruelty Prosecutions in Domestic Homicide and Violence Cases

Norwood, building on Oliphant, has several important implications for future cases involving children exposed to domestic violence or homicide:

No knowledge-of-presence requirement. Prosecutors need not prove that the defendant knew specific children were present at the time of a malicious act. It is enough that:
- The act was malicious (e.g., a purposeful violent assault or homicide); and
- Children under 18 actually experienced cruel or excessive mental pain as a result.
Multiple counts per event. A single malicious act can generate multiple first-degree child cruelty counts, one for each child traumatized. In Norwood, five such counts produced five consecutive 20-year sentences, on top of life without parole. This dramatically increases sentencing exposure in such cases.
Types of evidence supporting “excessive mental pain.” The opinion underscores the evidentiary value of:
- Forensic interviews of child witnesses describing fear, hiding, and emotional reactions;
- 911 calls capturing real-time panic;
- Testimony about ongoing nightmares, fears of recurrence, and physiological signs of distress.
These forms of evidence will likely be central in future prosecutions involving children exposed to violent crimes.
Policy signal: strong protection for children exposed to domestic violence. The decision reinforces a policy vision: children do not need to be direct physical targets to be victims in their own right. Witnessing or enduring the aftermath of a parent’s violent death can itself be prosecuted as first-degree cruelty to children.

B. Strategic Considerations for Defense and Prosecution

For defense counsel, Norwood suggests:

Arguments that the defendant “did not know” children were present will not defeat liability under § 16-5-70(b); the focus will shift to challenging the severity or causation of the alleged mental pain.
Cross-examination of child witnesses and adult caretakers will likely focus on whether distress was “excessive” versus typical grief or fear, though the threshold is relatively low given Oliphant and Norwood.

For prosecutors, the case:

Encourages charging first-degree child cruelty where children witness or are immediately exposed to severe violence;
Provides clear support for using forensic interviews, 911 recordings, and testimony about ongoing trauma to prove the mental pain element.

C. Motions for New Trial on the General Grounds

Norwood also has systemic implications for litigation strategy around general-grounds motions:

For trial courts: The opinion confirms that simply:
- Reciting the statutory standard from §§ 5-5-20 and 5-5-21, and
- Acknowledging the court’s discretion to weigh evidence and grant a new trial,
is generally sufficient to avoid reversal, absent explicit indication of a misunderstanding.
For appellate counsel: It will remain very difficult to overturn a denial of a new trial on the general grounds. Counsel must look for clear, affirmative statements in the record that the trial judge refused or misunderstood his or her “thirteenth juror” role—for example, language indicating the court believed it was bound by the jury’s weighing of the evidence.
For trial counsel: Lawyers seeking a robust “thirteenth juror” review may wish to:
- Make a clear record at the motion hearing, explicitly urging the court to weigh the evidence and credibility under §§ 5-5-20 and 5-5-21; and
- Request that the court confirm, on the record, that it has done so.
While not required, such practices can help ensure that the trial court fully engages its discretion and may create a better record for appellate arguments where appropriate.

VII. Conclusion

Norwood v. State is a significant reaffirmation and application of two core Georgia doctrines. First, it underscores that first-degree cruelty to children under OCGA § 16-5-70(b) reaches the severe mental trauma inflicted on children who witness or are exposed to a malicious act, even when the defendant does not know the children are present. The case confirms, in line with Oliphant, that the statute focuses on the malicious nature of the act and the actual suffering of the child—not on the defendant’s awareness of the child’s presence.

Second, the decision reinforces the limited scope of appellate review of general-grounds motions. Trial courts retain broad “thirteenth juror” discretion to evaluate the weight of the evidence and credibility of witnesses, but the Supreme Court will presume that discretion has been properly exercised when the court recites the correct standard and acknowledges its authority.

In domestic violence and homicide cases involving child witnesses, Norwood will likely encourage prosecutors to bring multiple first-degree child cruelty charges where children’s fear and trauma are evident. At the same time, it reminds practitioners that the primary battleground for contesting the weight of the evidence remains the trial court; once the general-grounds motion is denied under the correct standard, appellate relief will be rare.