Edmonson v. the State, 336 Ga. App. 621

Victim K.D., age 17, met Alfred Edmonson, age 41, for what she understood would be a paid sexual encounter; he drove her away from the agreed location, punched her, prevented her from leaving, and forced oral sex and intercourse at his home.
Edmonson was tried and convicted of false imprisonment and aggravated sodomy; acquitted of rape and other counts were nolle prossed or hung.
At trial the State introduced "other acts" evidence under OCGA § 24-4-404(b) describing Edmonson’s sexual encounters with a different teenage girl, N.R., including coercion and violence allegations.
The trial court admitted the other-acts evidence to show intent and plan; Edmonson objected and moved for a new trial, which was denied.
The Court of Appeals assumed, without deciding, that admission under § 24-4-404(b) might have been error but reviewed whether any error was harmless given the remaining evidence (victim testimony, officer observations, eyewitness Ealy, recorded jail call suggesting fabrication).
The court also noted the possibility the evidence might have been admissible under OCGA § 24-4-413 (similar-offense sexual-assault evidence) but did not decide that issue because it found any error harmless.

Issue	Edmonson's Argument	State's Argument	Held
Admissibility of N.R. "other acts" under OCGA § 24-4-404(b) to prove intent/plan	Admission was improper and prejudicial; other acts should be excluded	Other-acts evidence was relevant to show intent and plan (pattern of targeting vulnerable young women)	Court assumed possible error but did not decide admissibility; treated any error as harmless
Whether admission of the other-acts evidence was harmless error	Evidence of N.R. likely influenced jurors and contributed to conviction	Overwhelming independent evidence proved corpus of offenses; any error did not contribute to verdict	Harmless: highly probable the error did not contribute; conviction stands
Applicability of OCGA § 24-4-413 (similar sexual-offense evidence)	Not argued as primary basis at trial; procedural disclosure unclear	Evidence might have qualified under § 24-4-413 and thus been admissible on that ground	Court declined to decide § 24-4-413 applicability because harmless-error ruling made it unnecessary

Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence)
Peoples v. State, 295 Ga. 44 (harmless-error standard and de novo review of whether error contributed to verdict)
Bradshaw v. State, 296 Ga. 650 (standard of review for admission of OCGA § 24-4-404(b) evidence: abuse of discretion)
State v. Jones, 297 Ga. 156 (terminology and treatment of "other acts" under Georgia Evidence Code)
United States v. Felix, 503 U.S. 378 (acquittal does not bar admission of other-act evidence under a lower standard)
United States v. Beechum, 582 F.2d 898 (framework for analyzing admissibility of extrinsic offense evidence)
Parker v. State, 296 Ga. 586 (Georgia courts look to federal interpretations when Evidence Code mirrors federal rules)