Baughns v. the State, 335 Ga. App. 600

In November 2012 a three-person burglary crew committed a series of Athens‑Clarke County burglaries over about two weeks; Baughns primarily served as a driver and sold stolen goods.
From one burglary the crew obtained a handgun; during a November 26 burglary a co‑defendant shot and killed a homeowner when confronted.
Baughns was indicted with six burglaries naming him and five additional burglaries in the same multi‑defendant indictment that did not name him as a perpetrator. He was tried separately.
At trial the State introduced evidence of all eleven burglaries over Baughns’ objection as well as a recorded custodial interview from December 12, 2012 in which Baughns admitted transporting his co‑defendants to certain burglaries.
The jury convicted Baughns of aggravated assault (with a deadly weapon) and four first‑degree burglaries; he appeals, arguing (1) admission of the five uncharged burglaries was improper and (2) his custodial statement was involuntary because induced by a hope of benefit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of uncharged burglaries (intrinsic vs. extrinsic)	State: the other burglaries were part of the same burglary spree and intrinsic to complete the story	Baughns: the five burglaries that did not name him were extrinsic, minimally probative, and unfairly prejudicial under OCGA §§ 24‑4‑403 & 24‑4‑404(b)	Court: admissible as intrinsic/res gestae — same method, time frame, area, overlapping participants; no abuse of discretion
Admissibility of custodial confession (induced by hope of benefit)	State: statements encouraging honesty and noting cooperation would be reported do not promise reduced charges/sentence	Baughns: investigators’ remarks (wanting to tell judge/prosecutor he cooperated; suggesting honesty could change outcome) created a hope of benefit rendering confession involuntary under OCGA § 24‑8‑824	Court: confession voluntary under totality; promises were nonspecific and did not relate to charges/sentence, so admissible

Jackson v. Virginia, 443 U.S. 307 (standard for viewing evidence in light most favorable to the verdict)
Reeves v. State, 294 Ga. 673 (appellate review of evidentiary rulings: abuse of discretion)
Brown v. State, 290 Ga. 865 (interpretation of "slightest hope of benefit" in confession context)
State v. Chulpayev, 296 Ga. 764 (promise of benefit must relate to charge or sentence to render confession involuntary)
Carter v. State, 269 Ga. 891 (admission of offenses as part of a crime spree/res gestae)
Edouard v. United States, 485 F.3d 1324 (federal articulation of intrinsic‑evidence principles)