Cook v. State, 312 Ga. 299

Charles Cook was indicted for malice murder and related firearms offenses after Salanto Winfrey was shot three times and killed; Cook was convicted and sentenced to life plus five years.
Multiple witnesses placed Cook as the shooter; autopsy showed two fatal shots to Winfrey’s back and one to his thigh.
Cook’s defense was self-defense/voluntary manslaughter: he claimed Winfrey had threatened him, had a history of violence, and had on the night in question fetched a gun from upstairs.
The defense presented testimony about a prior physical altercation between Cook and Winfrey over a parking space and multiple witnesses attesting to Winfrey’s violent reputation and that he carried a gun.
Cook sought to admit three additional instances of Winfrey’s violence toward third parties (slapping/throwing an elderly man, striking an older man with a rake, and punching a man off a porch); the trial court excluded those specific acts.
On appeal Cook argued the exclusion was error; the Georgia Supreme Court affirmed, concluding any error was harmless because the excluded acts were cumulative of other, admitted evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exclusion of evidence of three prior violent acts by the victim	Cook: the specific incidents were admissible to show fear, victim’s propensity for violence, and self-defense justification	State: exclusion did not affect Cook’s substantial rights because the jury already heard ample evidence of Winfrey’s violence, threats, and carrying a gun	Court affirmed; even if exclusion was erroneous, it was harmless beyond a reasonable probability because the proffered incidents were cumulative of admitted evidence

Neuman v. State, 311 Ga. 83 (2021) (harmless-error and substantial-rights principles governing review of evidentiary rulings)
Truett v. State, 311 Ga. 313 (2021) (standard for nonconstitutional harmless error: whether error likely did not contribute to the verdict)
Peterson v. State, 274 Ga. 165 (2001) (additional evidence of prior violent acts held cumulative and its exclusion harmless)
Sturkey v. State, 271 Ga. 572 (1999) (exclusion of testimony about threats harmless where jury heard ample evidence of victim’s violence)
Henderson v. State, 310 Ga. 708 (2021) (excluded testimony that added little to already-admitted evidence will be harmless)