Dennis v. State, 293 Ga. 688

On August 26, 2009, Amin Dennis and his brother Corey ambushed Jerry Lee Lawrence and Harold Reese, bound them with electrical ties and duct tape, shot both victims, burned Reese’s vehicle with Lawrence’s charred body inside, and attempted to destroy evidence at home burn piles.
Police later recovered Lawrence’s body in the burned vehicle and Reese’s body nearby; physical evidence linked the brothers to the victims and vehicles (keys, matching padlock/door, clothing, personal effects, and similar electrical ties).
Dennis made inculpatory statements to a cousin shortly after the killings and later gave a videotaped custodial statement to police; he signed a standard waiver of rights form during interrogation.
At trial a jury convicted Dennis of multiple counts including malice murder, kidnapping with bodily injury, armed robbery, arson, and related firearm offenses; he received consecutive life and term sentences.
On appeal Dennis challenged (1) sufficiency of evidence for the kidnapping-with-bodily-injury counts (arguing no movement of victims) and (2) admissibility of his videotaped confession as not knowingly, intelligently, and voluntarily made (alleging officers suggested lighter punishment).

Issue	Dennis's Argument	State's Argument	Held
Sufficiency of evidence for kidnapping with bodily injury (movement element)	Dennis: No evidence victims were moved; movement element not met.	The State: Victims were removed from vehicle, bound, concealed/isolated, and placement in vehicle facilitated robbery/murders; slight movement suffices.	Court: Evidence (including Dennis’s statement) shows movement that concealed/isolated victims and made the crimes easier; convictions upheld.
Admissibility of custodial statement (voluntariness; promise of leniency)	Dennis: Officers’ statements (e.g., ‘‘do something big,’’ co-defendant cooperated) implied hope of benefit or promise of leniency, so waiver involuntary.	The State: Officer remarks were encouragements to tell truth, no promises of reduced punishment; Dennis signed waiver and appeared to understand rights.	Court: Trial court correctly found waiver knowing and voluntary; remarks were not promises of benefit; statement admissible.

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
Jackson v. Denno, 378 U.S. 368 (voluntariness of confessions and pretrial suppression hearing procedures)
Taylor v. State, 274 Ga. 269 (confession must be voluntary and not induced by hope of benefit)
Brown v. State, 290 Ga. 865 (hope of benefit arises from promises of reduced punishment)
Bunnell v. State, 292 Ga. 253 (State’s burden to prove waiver by preponderance)
Vergara v. State, 283 Ga. 175 (de novo review when controlling facts undisputed, e.g., videotape)
Daniel v. State, 285 Ga. 406 (use of deceit/trickery does not automatically render confession inadmissible)