Carpenter v. State, 305 Ga. 725

On Aug. 11, 2016 Lucio Vasquez was shot and later died after meeting with Benjamin Carpenter, Christian Hernandez, and Tyler Wofford; Carpenter was sitting in the backseat and a .25-caliber bullet was recovered from that area.
Hernandez identified events and later cooperated with the prosecution; Carpenter's DNA was found in the backseat and ballistics were consistent with a Raven .25-caliber handgun.
A grand jury indicted Carpenter and Hernandez on multiple counts including murder and possession of a firearm during the commission of a felony; Hernandez later pleaded to reduced charges and testified against Carpenter.
Carpenter was tried in May 2017, acquitted of malice murder and some assault counts, but convicted of murder in the commission of an attempted armed robbery and possession of a firearm during the commission of a felony; he received life imprisonment.
On appeal Carpenter challenged evidentiary rulings (limitations on cross-examination and admission of testimony about gun sourcing) and the trial court’s conspiracy charge; the Georgia Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Carpenter argued convictions not supported	State argued evidence (DNA, ballistics, ID, testimony) sufficient	Affirmed — evidence sufficient under Jackson v. Virginia standard
Limitation on cross-examination (OCGA § 24-4-404(b))	Carpenter sought to elicit Hernandez's prior threat to show motive/retribution	State argued prior threat was propensity evidence and not logically necessary to prove motive	Affirmed — trial court did not abuse discretion; prior threat was not admissible to show motive here
Conspiracy jury instruction wording	Carpenter argued charge was misleading because it failed to specify the unlawful enterprise as armed robbery, risking liability for unrelated marijuana purchase	State argued whole charge and other instructions made predicate felonies and burden clear	Affirmed — charge considered as a whole not misleading; jury properly instructed on predicate felonies and scope of conspirator liability
Admission of testimony about source of handguns	Carpenter claimed prosecution breached a pretrial agreement not to present such evidence	State said no such agreement appears in record; only a different agreement limited unrelated firearms evidence	Affirmed — no pretrial agreement was found that barred this testimony

Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency of the evidence standard)
Brooks v. State, 298 Ga. 722 (discusses limits on extrinsic evidence to prove motive vs. propensity)
State v. Jones, 297 Ga. 156 (related authority on other-acts evidence limits)
Edge v. State, 275 Ga. 311 (permissible to instruct on conspiracy even if not alleged in indictment)
Mister v. State, 286 Ga. 303 (conspiracy instruction may refer to "unlawful enterprise" without specifying object when appropriate)
Salahuddin v. State, 277 Ga. 561 (instructional errors assessed by considering charges as a whole)
Ware v. State, --- Ga. ---, 826 S.E.2d 56 (jury charges must tie felony-murder liability to predicate felony as proximate cause)