Doyle v. State, 307 Ga. 609

Matthew Doyle was convicted by a jury of malice murder and possession of a firearm during the commission of a felony for the December 17, 2010 shooting death of Lyndon “Pookie” Tucker; sentence: life without parole plus 10 years consecutive.
Key eyewitness was Keith Richardson, who testified he drove Doyle and co-defendant Lewis Parks to the scene, saw or heard about guns, heard shots, and drove the men away; Richardson was the only witness who affirmatively identified Doyle as a participant.
A neighbor heard shots and saw a blue SUV; cell‑phone records placed Parks near the scene but did not place Doyle there.
Detective testified that a witness, Kerry Henderson, told him Parks ("Fat Lewis") and a “Matthew” admitted to the shooting; Henderson identified Parks at trial but did not identify Doyle in court.
Trial court instructed the jury that a single witness, if believed, is sufficient to establish a fact (single‑witness charge) and did not give the accomplice‑corroboration instruction; Doyle did not request or object to that omission at trial.
On appeal the Georgia Supreme Court held that the omission of the accomplice‑corroboration instruction was plain error and reversed Doyle’s convictions (state may retry).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to convict Doyle	Doyle argued insufficient evidence because Richardson was an accomplice and lacked independent corroboration linking Doyle	State argued evidence (Richardson’s testimony, Henderson/detective testimony, cell records for Parks) was sufficient corroboration	Court: Evidence was legally sufficient to permit conviction, i.e., constitutional sufficiency satisfied (Jackson standard)
Failure to instruct jury on accomplice‑corroboration requirement (plain error)	Doyle argued trial court erred by not instructing jury to determine whether Richardson was an accomplice and by not giving accomplice‑corroboration charge	State argued Richardson was not an accomplice and that corroborating evidence (Henderson/detective) was adequate; thus no instruction required	Court: Omission was clear and obvious error under plain‑error review; given centrality of Richardson’s testimony and the single‑witness instruction, error likely affected outcome; reversed

Jackson v. Virginia, 443 U.S. 307 (establishes constitutional standard for sufficiency of the evidence)
Puckett v. United States, 556 U.S. 129 (plain‑error test articulated for appellate review)
Lewis v. State, 301 Ga. 759 (corroboration may be slight and circumstantial; must be independent of accomplice)
Hamm v. State, 294 Ga. 791 (failure to give accomplice‑corroboration instruction reviewed for plain error when not preserved)
Walter v. State, 304 Ga. 760 (jury must be instructed on accomplice liability where slight evidence supports that finding)
Stanbury v. State, 299 Ga. 125 (failure to give accomplice‑corroboration instruction undermines fairness when conviction rests on accomplice testimony)
Lyman v. State, 301 Ga. 312 (holding that single‑witness instruction without accomplice corroboration language is error)
Johnson v. State, 305 Ga. 237 (same instructional error discussed)
Vasquez v. State, 306 Ga. 216 (examples of circumstances supporting accomplice finding)
Belsar v. State, 276 Ga. 261 (criminal intent may be inferred from presence, companionship, and conduct)