Alatise v. State, 291 Ga. 428

Alatise was convicted of felony murder and aggravated assault after a jury trial for the shooting of Mendoza-Garcia.
Javon, Alatise’s co-defendant, implicated Alatise and provided statements corroborated by independent investigative findings.
Fingerprint evidence placed Alatise in a stolen Acura Integra associated with the case.
The State introduced multiple similar-transaction robberies to show modus operandi and corroborate Javon’s testimony.
The jury heard, and later watched, parts of a videotaped interview; a curative instruction was given after discovery of extraneous material.
Alatise challenges multiple evidentiary rulings and the sufficiency of the evidence; the trial court denied relief and the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Alatise argues the evidence did not prove guilt beyond a reasonable doubt.	State contends witness corroboration and similar-transaction evidence support guilt.	Evidence sufficient to support guilt beyond a reasonable doubt
OCGA § 24-9-85 plain error	Alatise requested a charge or objected, insisting on the additional instruction.	State argues the omission was harmless given the full charge on impeachment and credibility.	Omission harmless error; no reversal
Probable cause and suppression of statements	Alatise asserts arrest lacked probable cause based on Javon’s statements.	State maintains corroboration from independent investigation and Javon’s confession provided reasonable basis.	No suppression error; probable cause supported
Admissibility of similar transactions	Ten similar transactions were not sufficiently similar to the charged crime.	Similar-transaction evidence showed modus operandi and corroborated Javon’s testimony.	Similar transaction evidence properly admitted
Directed verdict and corroboration of co-defendant	Sought directed verdict due to lack of independent corroboration.	Javon’s testimony was corroborated by numerous similar transactions and fingerprint evidence.	No error; substantial corroboration supported verdict

Jackson v. State, 443 U.S. 307 (U.S. Supreme Court 1979) (sufficiency review for evidence in criminal cases)
Evans v. State, 209 Ga. App. 340 (Ga. App. 1993) (harmless error analysis of evidentiary issues)
Morgan v. State, 241 Ga. 485 (Ga. 1978) (corroboration requirements for accomplice testimony)
Perryman v. State, 63 Ga. App. 825 (Ga. App. 1940) (corroboration through connected acts in corroborating conduct)
Chua v. State, 289 Ga. 220 (Ga. 2011) (standards for admissibility of similar-transaction evidence)