Bradshaw v. State
296 Ga. 650
| Ga. | 2015Background
- On June 25, 2011, Christopher Bradshaw and Michael Boykin arranged a marijuana purchase from Devonta Stembridge; Bradshaw sat in the backseat and, according to Boykin, produced a chrome semi-automatic handgun and shot Stembridge and Dion Brice, both of whom died.
- Boykin fled, then returned and saw Bradshaw running; Bradshaw discarded a cap and white t-shirt near the scene and later threatened Boykin if he told anyone.
- Forensic evidence linked 9mm casings and two bullets to a handgun recovered from Bradshaw’s apartment; a cap and t-shirt found near the car bore Bradshaw’s DNA and Stembridge’s blood.
- The State introduced evidence of an earlier Ohio murder (six months prior) in which Bradshaw allegedly admitted killing Jeffery Beans by shooting him in the head; the trial court admitted that evidence for intent, motive, and identity under OCGA § 24-4-404(b).
- Bradshaw was convicted of malice murder and related counts (tampering count directed as a verdict for the defense); he appealed, arguing insufficient evidence (including inadequate corroboration of accomplice Boykin) and erroneous admission of the Ohio murder as similar-transaction evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to support convictions | State: Evidence (forensics, clothing, DNA, Boykin testimony) establishes guilt beyond reasonable doubt | Bradshaw: Only uncorroborated accomplice testimony (Boykin) links him to the shootings; without similar-transaction evidence, insufficent | Court: Evidence sufficient; accomplice testimony was corroborated by independent forensic and physical evidence (weapon, clothing, DNA) and admissible similar-transaction evidence was considered |
| Whether accomplice testimony required corroboration under new Evidence Code | State: New Code preserves prior corroboration standard; corroboration may be slight and circumstantial | Bradshaw: Boykin’s testimony was uncorroborated and therefore cannot support conviction | Court: OCGA § 24-14-8 carries same meaning as prior law; accomplice testimony was corroborated sufficiently by independent evidence |
| Admissibility of prior Ohio murder under OCGA § 24-4-404(b) (similar transaction) | State: Prior murder relevant to intent, motive, and identity; probative value not substantially outweighed by prejudice; jury could find prior crime by preponderance | Bradshaw: Prior-act evidence was unfairly prejudicial and should have been excluded | Court: Applied Eleventh Circuit three-part test (relevance to non-character issue, balancing under §403, and sufficient proof by preponderance) and held the evidence admissible; trial court did not abuse discretion |
| Consideration of erroneously admitted evidence in sufficiency review | State: Court may consider all evidence admitted at trial in reviewing sufficiency; Cowart and new Evidence Code support this approach | Bradshaw: If similar-transaction evidence were improperly admitted, it should not be considered for sufficiency | Court: Even if improperly admitted, reviewing court may consider evidence the trial court admitted when assessing sufficiency; here admission was proper anyway |
Key Cases Cited
- Cowart v. State, 294 Ga. 333 (Ga. 2013) (reviewing court may consider all evidence admitted by trial court in sufficiency review)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for sufficiency review: whether any rational trier of fact could find guilt beyond a reasonable doubt)
- Threatt v. State, 293 Ga. 549 (Ga. 2013) (corroboration of accomplice testimony may be slight, circumstantial, and need only identify defendant as participant)
- Huddleston v. United States, 485 U.S. 681 (U.S. 1988) (standard for preliminary factual findings under Rule 104(a) is preponderance of the evidence)
- United States v. Ellisor, 522 F.3d 1255 (11th Cir. 2008) (three-part test for admissibility of other-acts evidence under Rule 404(b))
- United States v. Edouard, 485 F.3d 1324 (11th Cir. 2007) (relevance of other-act evidence to intent when mental state parallels charged offense)
- Bourjaily v. United States, 483 U.S. 171 (U.S. 1987) (preponderance standard for preliminary admissibility findings under Rule 104(a))