Carter v. State, 324 Ga. App. 118

Carter was convicted of armed robbery based on accomplice Harris and Suggs' testimony and additional investigative evidence.
Suggs and Harris testified to Carter driving them to the store, waiting outside, and Carter's involvement as the driver; Harris also testified Carter received some stolen money.
The detective connected the trio via Facebook photos and a store video, and overheard a conversation between Suggs and Carter about the robbery.
Suggs initially admitted being in the store and later identified Harris in a photo lineup; Harris also linked Carter to the crime and the money.
Carter gave multiple statements to investigators, with inconsistencies among them; all three women were indicted, with Suggs and Harris pleading guilty to a lesser offense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was sufficient corroboration of Harris's accomplice testimony	Carter contends Harris's testimony alone is insufficient.	State argues independent corroboration exists through Suggs and detective testimony.	Corroboration found; sufficient for conviction.
Whether trial counsel was ineffective for not objecting to hearsay about the anonymous tipster	Hearsay was prejudicial and unsupported by necessity or relevance.	Failure to object was not prejudicial given other evidence and did not change outcome.	No ineffective assistance; objection would have been overruled.
Whether trial counsel was ineffective for failing to object to questions about pre-arrest silence and for closing argument	Questions about silence and closing argument violated rights and prejudiced defense.	Questions concerned inconsistent statements; Mallory limitation does not apply; closing was proper.	No ineffective assistance; questions and closing were permissible.

Robinson v. State, 314 Ga. App. 545 (2012) (standard of viewing evidence in light most favorable to verdict)
Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency of evidence standard for federal review)
Crawford v. State, 210 Ga. App. 36 (1993) (accomplice corroboration and credibility considerations)
Hillman v. State, 296 Ga. App. 310 (2009) (corroboration of accomplice testimony principles)
Crowe v. State, 83 Ga. App. 325 (1951) (early corroboration framework for accomplice testimony)
Felton v. State, 283 Ga. 242 (2008) (hearsay exceptions and admissibility in corroboration contexts)
Mallory v. State, 261 Ga. 625 (1991) (Mallory principle on silence and comment considerations)
Yancey v. State, 292 Ga. 812 (2013) (permissibility of questions about silence and omissions post-arrest)
Curry v. State, 291 Ga. 446 (2012) (inquiry into silence and consistency during statements)
McMichen v. State, 265 Ga. 598 (1995) (purpose of questions about omissions and consistency)
Gilyard v. State, 288 Ga. 800 (2011) (timely objections and silence-related testimony)
Bradley v. State, 292 Ga. 607 (2013) (closing argument latitude and meritless objections)
Romer v. State, 293 Ga. 339 (2013) (evidence code considerations and silence-related questions)