Daniels v. the State
339 Ga. App. 837
| Ga. Ct. App. | 2016Background
- On Oct. 8, 2013, Quincy Driskell testified that Marquise Daniels planned a convenience-store robbery: Daniels would buy one cigarette to prompt the clerk to open the register while Driskell—masked and armed—grabbed the money.
- Surveillance video showed Daniels enter first, converse with the clerk, signal for a cigarette, lean on the counter while Driskell donned a mask, displayed a gun, reached toward the register, then run out; Driskell followed seconds later and also fled with cash.
- A neighbor witness saw two men run out in the same direction within seconds; Daniels and Driskell ran to Daniels’ mother’s house, were later driven together, and exited at the same location.
- Daniels initially denied knowing Driskell or involvement, then admitted knowing Driskell but continued to deny participation; Daniels’ mother identified Driskell on video and later confirmed both were together after the robbery.
- Daniels was convicted as a party to armed robbery, aggravated assault, and possession of a firearm during the commission of a felony; he appealed claiming the accomplice’s testimony (Driskell) lacked independent corroboration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Driskell’s accomplice testimony was sufficiently corroborated to support convicting Daniels as a party | State: surveillance, eyewitness timing, joint flight and post-robbery conduct, and Daniels’ lies to police independently corroborate Driskell and connect Daniels to the crime | Daniels: evidence at most shows presence/timeline; no independent proof he planned, supplied the gun/mask, or participated — mere presence insufficient | Court affirmed: corroborating evidence (circumstantial, slight) was independent and sufficient to authorize jury conviction |
Key Cases Cited
- Brown v. State, 291 Ga. 750 (2012) (standard for construing evidence to support verdict)
- Cisneros v. State, 299 Ga. 841 (2016) (accomplice testimony cannot alone support felony conviction; corroboration requirement)
- Threatt v. State, 293 Ga. 549 (2013) (corroboration may be slight or circumstantial; false statements can corroborate)
- Chandler v. State, 311 Ga. App. 86 (2011) (corroborating facts must independently connect defendant with crime)
- Taylor v. State, 297 Ga. 132 (2015) (evidence that only corroborates chronology/details is insufficient)
- Hill v. State, 236 Ga. 831 (1976) (corroboration must do more than create grave suspicion)