Foster v. State, 304 Ga. 624

Victim Kenneth Scott ("Stuntman") cashed his paycheck and left work at U.S. Foods the night of Aug. 16–17, 2012; his last phone calls were to Jerome Foster.
Foster (a janitorial employee) met Scott under a pretext; Foster and Andrew Ball lured, beat, robbed, and strangled Scott; Scott's body was found days later with signs consistent with robbery and strangulation.
Physical evidence tied Foster to the crime scene and aftermath: a bloody washcloth at Foster's home, allegedly blood-stained laundered pants in his car, Foster admitted being with Scott and Ball that night, and Foster helped burn Scott’s truck.
Ball (an accomplice) did not testify at trial; third parties testified about statements Ball made to them describing Foster's role. Foster (pro se) did not object to admission of that hearsay.
Foster was convicted by a jury of malice murder, felony murder counts, robbery by force, and aggravated assault with intent to rob; he appealed arguing insufficient corroboration of the accomplice's statements.

Issue	Foster's Argument	State's Argument	Held
Whether Ball's out-of-court statements (accomplice evidence) were insufficiently corroborated to support convictions	Ball's statements were the only source linking Foster to the killing and lacked adequate independent corroboration	Independent circumstantial evidence (calls, admissions, physical evidence, conduct before/after) corroborated Ball's account	Corroboration was sufficient; convictions affirmed
Whether hearsay admission required objection to preserve challenge	Implied that accomplice-style corroboration required even for hearsay recounting an accomplice's statements	Foster waived hearsay objection by not objecting; appellate counsel did not challenge admissibility	Court pretermitted whether statutory accomplice-corroboration applies to hearsay but relied on independent corroboration anyway
Whether evidence met Jackson v. Virginia due process standard	Argues insufficient evidence to permit a rational jury to convict beyond reasonable doubt	Argues cumulative evidence satisfied the standard	Court held evidence sufficient under Jackson
Whether sentencing/count merger issues affected convictions on appeal	(Not contested on this appeal)	(Not contested)	Judgment and sentences affirmed (felony-murder counts vacated by law; merger addressed at trial)

Faretta v. California, 422 U.S. 806 (recognition of right to proceed pro se)
Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence under due process)
Threatt v. State, 293 Ga. 549 (2013) (explains accomplice corroboration standard)
Parkerson v. State, 265 Ga. 438 (1994) (conduct before and after a crime may support an inference of guilt)
Malcolm v. State, 263 Ga. 369 (1993) (procedural rule re: vacating felony-murder counts)
Lawrence v. State, 342 Ga. App. 396 (2017) (discusses accomplice statements introduced through other witnesses)