Coe v. State, 293 Ga. 233

Coe was convicted of malice murder, possession of a firearm during the commission of a felony, and possession of a firearm by a convicted felon in connection with Johnny Davis's death; the murder occurred during a gunfight involving Mingledolph and others.
Approximately a year before the killing, Coe allegedly stole marijuana from Donte Simmons, an associate of Mingledolph.
On the day of the shooting, Mingledolph and associates confronted Coe, taking his belongings and encouraging him to shoot; Coe fled.
During the ensuing gunfight, Coe fired a 10mm pistol and Mingledolph fired a 9mm pistol; Davis, seated in a nearby pickup, was killed by a gunshot.
The State argued transferred intent made Coe criminally liable for Davis's death regardless of who fired the fatal shot, and the jury convicted Coe on all charges.
The court affirmed all judgments, and Coe’s challenges to severance, voir dire, mistrial, and related issues were rejected.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of malice murder via transferred intent	Coe argues insufficient evidence of his intent to kill Davis.	State argues transferred intent makes Coe culpable regardless of who fired the fatal shot.	Sufficient evidence to sustain malice murder under transferred intent.
Potential juror bias from acquaintance with a witness	Coe contends juror could not be impartial due to familiarity with the widow.	State contends no bias or fixed opinion existed.	Trial court did not abuse discretion; juror remained on the panel.
Severance of Coe and Mingledolph	Coe argues motion to sever should have been granted.	There was no proper basis to grant severance given joint trial and similar law.	No abuse of discretion in denying severance.
Mistrial due to parole mention	Improper mention of parole warranted mistrial.	No motion for mistrial was properly preserved; decision to not curtail remarks was harmless.	Waived; if preserved, no reversible error.

Hendricks v. State, 290 Ga. 238 (Ga. 2011) (transferred intent governs liability where the principal is the target or an accomplice)
Love v. State, 268 Ga. 484 (Ga. 1997) (intent may be inferred from conduct; transferred intent concepts apply)
Poole v. State, 291 Ga. 848 (Ga. 2012) (disqualification and burden of showing bias; discretion of trial court)
Butler v. State, 290 Ga. 412 (Ga. 2012) (severance discretion factors in two-defendant cases)
Loren v. State, 268 Ga. 792 (Ga. 1997) (antagonistic defenses alone do not mandate severance; show prejudice required)
Krause v. State, 286 Ga. 745 (Ga. 2010) (need for showing specific prejudice in joint trials)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (requisite standard for sufficiency of evidence)