Ardis v. State, 290 Ga. 58

Ardis was convicted of felony murder, aggravated assault, and related offenses for a shooting death and an aggravated assault.
The evidence showed a black Monte Carlo, a red temporary tag, eyewitness driver identification, and ammunition matching a 9mm handgun.
Ardis admitted to a friend that he fired a 9mm in the parking lot and planned to rob the drug dealer.
Dana Bazile owned the Monte Carlo; Ardis had access to the car at the time of the shooting.
Eleven 9mm shell casings and the victim’s bullet were recovered and fired from the same gun; co-defendant West gave a custodial statement redacted to remove Ardis’s name.
The trial court admitted West’s redacted statement and Langston’s out-of-court statement; severance was denied and the weapon in Ardis’s home was admitted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Ardis argues insufficient evidence to support guilt beyond a reasonable doubt.	State contends the evidence, viewed in the light most favorable to the verdict, supports guilt.	Evidence sufficient for guilt beyond a reasonable doubt.
Bruton error from co-defendant West’s redacted statement	Ardis argues Sixth Amendment confrontation violation from West’s redacted statement.	State contends Bruton violation not reversible due to lack of prejudice.	Bruton violation found, but harmless beyond a reasonable doubt.
Admission of Langston’s testimonial statement under Crawford	Ardis claims Langston’s testimonial statement was improperly admitted without opportunity to cross-examine.	State contends admissibility met Crawford requirements and any error was not prejudicial.	Crawford violation found; but no reasonable likelihood of different outcome due to overwhelming other evidence.
Admission of guns and ammunition found at Ardis’s home	Ardis argues testimony regarding guns/ammunition found at home was inadmissible.	State asserts evidence was relevant to felon-in-possessory-firearm charge and admissible.	Admission deemed permissible; not reversible error.
Motion for severance	Ardis argues severance should have been granted due to Bruton issue and potential prejudice.	Westmoreland factors weigh against severance; no clear prejudice shown.	No abuse of discretion; severance denied.

Jackson v. Virginia, 443 U. S. 307 (U.S. 1979) (sufficiency of evidence standard)
Bruton v. United States, 391 U. S. 123 (U.S. 1968) (confrontation clause with non-testifying co-defendant statements)
Davis v. State, 272 Ga. 327 (Ga. 2000) (redacted statements can still violate Bruton if they reference the defendant)
Crawford v. Washington, 541 U. S. 36 (U.S. 2004) (testimonial statements of unavailable declarants require cross-examination)
Schneble v. Florida, 405 U. S. 427 (U.S. 1972) (harmless error standard for Bruton-type violations)
Burgess v. State, 278 Ga. 314 (Ga. 2004) (harmless error analysis for Bruton-related issues)
Mason v. State, 279 Ga. 636 (Ga. 2005) (severance considerations and prejudice analysis)
Dorsey v. State, 273 Ga. 754 (Ga. 2001) (severance and prejudice standards for joint trials)
Westmoreland v. State, 287 Ga. 688 (Ga. 2010) (trial court's severance discretion factors)