Bradley v. State, 292 Ga. 607

Bradley was convicted by a Lowndes County jury of malice murder, aggravated assault, armed robbery, and three firearm-possession charges tied to the crimes.
Evidence showed two men robbed the AB Food Mart in Valdosta on Oct. 15, 2003; one shooter killed Natavarlal Patel and wounded Bobby Patel, while the second man took about $1,500.
A revolver consistent with the crime was later recovered from Michael Thomas, and a criminologist linked it to the weapon used in the robbery.
Two years later, a woman overheard Bradley say he robbed the store and had given the weapon to a man named “Mike Thomas”; Bradley disclosed similar details in a recorded informant conversation.
The informant, including a recorded conversation, testified at trial; Pounder (the co-perpetrator known as “Jay”) testified Bradley recruited him for the robbery.
The trial court excluded certain third-party statements as unreliable; the court later addressed admissibility of prior consistent statements from the informant and the recorded confession.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support convictions	Bradley argues evidence insufficient to convict.	State contends evidence viewed for credibility supports verdict.	Evidence sufficient to sustain convictions.
Merger of firearm-possession convictions	Bradley asserts multiple possession counts should merge with predicate offenses.	State argues statute allows multiple possessions for separate victims.	Two possession convictions stood; one must be vacated; merger warranted for others.
Merger of aggravated assault with armed robbery	Bradley seeks merger based on same act/transaction.	State contends aggravated assault and armed robbery are distinct acts.	Aggravated assault merged into armed robbery; remaining conviction vacated.
Admission of statements about other possible participants	Bradley contends excluded statements were necessary for defense.	State argues statements unreliable; exclusion proper.	Trial court did not abuse discretion; due-process concerns not met.
Effect of the recording during jury deliberations and prior consistent statements	Bradley claims recording and prior statements violated rules and affected fair trial.	State asserts no replay occurred and statements were properly admitted or non-prejudicial.	No reversible error; evidence admissibility and impact deemed non-prejudicial.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for criminal convictions)
State v. Marlowe, 277 Ga. 383 (Ga. 2003) (firearm-possession and multiple predicate offenses merger guidance)
Grell v. State, 291 Ga. 615 (Ga. 2012) (merger principles and admissibility considerations)
Long v. State, 287 Ga. 886 (Ga. 2010) (no element of aggravated assault with deadly weapon not in armed robbery; merger discussion)
Thomas v. State, 289 Ga. 877 (Ga. 2011) (act/transaction merger for aggravated assault and armed robbery)