Crawford v. State, 294 Ga. 898

Crawford was convicted of felony murder, burglary, and false imprisonment for a March 25, 2008 home invasion of Tedla Lemma.
Lemma was bound, beaten, suffocated, and left with an adult diaper over his face; death due to mechanical obstruction plus blunt force trauma.
State’s key witness Araya testified as the mastermind of the burglaries and described the plan and execution involving Crawford.
Araya testified about three prior staged burglaries and that Crawford joined the March 25 plan; timing and method were discussed beforehand.
Cell phone records and tower data tied multiple defendants to the Lemma residence and to Crawford’s residence during the relevant timeframe.
There were no eyewitnesses linking Crawford; the case rested on Araya’s testimony corroborated by circumstantial cellphone evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of corroboration for accomplice testimony	Crawford argues Araya’s testimony alone suffices without independent corroboration.	Crawford contends insufficient independent evidence to corroborate identity and participation.	Sufficient corroboration existed; phone records linked Crawford to the crime independently of Araya.
Admission of co-conspirator hearsay	Araya’s testimony about Jackson’s statement is admissible as a co-conspirator hearsay under the prior framework.	Hearsay should be excluded as improperly admitted under the conspired statements rule.	Correctly admitted; there was prima facie conspiracy evidence apart from the statement and the statement was made during the project.
Jury instruction on conspiracy	Instruction warranted given evidence of conspiracy among Araya, Jackson, Brooks, and Crawford.	No conspiracy to be charged; insufficient evidence to support conspiracy instruction.	Conspiracy instruction proper; slight evidence supported the charge.

Johnson v. State, 288 Ga. 803 (Ga. 2011) (corroboration requirement for accomplice testimony; independent evidence needed)
Selvidge v. State, 252 Ga. 243 (Ga. 1984) (corroboration of identity and participation permissible via slight extrinsic evidence)
West v. State, 232 Ga. 861 (Ga. 1974) (corroboration must tend to show defendant’s participation beyond chronology)
Gunter v. State, 243 Ga. 651 (Ga. 1979) (corroboration sufficient to sustain conviction when independent evidence links defendant)
Williams v. State, 280 Ga. 584 (Ga. 2006) (extremely light corroboration may support submission to jury)
Kesler v. State, 249 Ga. 462 (Ga. 1982) (corroboration required to connect defendant with crime)
Birt v. State, 236 Ga. 815 (Ga. 1976) (corroboration must implicate defendant, not solely chronology)
Griffin v. State, 294 Ga. 325 (Ga. 2013) (conspiracy defined by agreement; conduct may reveal common design)
Lewis v. State, 291 Ga. 273 (Ga. 2012) (co-conspirator statements admissible if conspiracy exists and case independent of hearsay)
Lombardi, Inc. v. Smithfield, 11 A.3d 1180 (Del. 1989) (irreparable harm is the most important factor for a preliminary injunction)