English v. State
300 Ga. 471
| Ga. | 2017Background
- Victim Ricky Payne was found burned on a couch after a house fire; medical examiner ruled death from blunt force head trauma; clothing tested positive for an ignitable fluid and a lighter and lighter fluid were recovered.
- James English was at the house earlier that evening and later told multiple acquaintances he had fought with and struck Payne, and (according to witnesses) that he had killed Payne and set the couch on fire.
- Two witnesses (Howell and Carrigg) recorded English asking them to fabricate an alibi and admitting incriminating facts; they later reported this to GBI investigators.
- English gave custodial statements to police admitting he struck Payne repeatedly but denying he killed Payne or started the fire.
- English was convicted by a jury of malice murder and first-degree arson and sentenced to life plus concurrent 10 years; he appealed claiming the trial court plainly erred by not charging the jury on corroboration of confessions under former OCGA § 24-3-53.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court plain error for failing to instruct jury that an uncorroborated confession cannot alone justify conviction | English: court should have instructed jury that confessions require corroboration and absence of that charge was plain error | State: most statements were admissions (not confessions) and, even if confessions, there was abundant corroboration so no effect on outcome | No plain error: statements to police were admissions, and ample corroboration existed; omission did not affect substantial rights |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)
- Robinson v. State, 232 Ga. 123 (1974) (distinguishing admissions from confessions)
- Lowe v. State, 267 Ga. 180 (1996) (defining confession as admission of entire criminal act)
- State v. Kelly, 290 Ga. 29 (2011) (plain-error review for jury instruction claims under OCGA § 17-8-58(b))
- Stanbury v. State, 299 Ga. 125 (2016) (articulating the four-prong plain-error test)
- Rashid v. State, 292 Ga. 414 (2013) (addressing corroboration requirement and plain-error burden)
- Hamm v. State, 294 Ga. 791 (2014) (discussing requests for corroboration-of-confessions charge)