Francois v. State, 309 Ga. App. 692

Francois was convicted of aggravated battery, possession of a firearm during a felony, and five counts of aggravated assault with a deadly weapon based on a March 15, 2007 shooting of Cofield.
Cofield identified Francois in a photo lineup and at trial as the shooter after observing him near a white Impala.
Witnesses saw a shooter emerge from a white Impala, shoot into a crowd, then return to the Impala and drive away.
The State introduced hearsay testimony from two officers about third-party statements linking Francois to the white Impala.
Francois objected to the officers' statements as hearsay; the court admitted the testimony, and the defense later did not timely object to some related questions.
Francois challenged the admission as error but the appellate court found any error harmless or unpreserved.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Hearsay links to the Impala admissible?	Francois argues officers’ hearsay tied him to the Impala.	Francois claims admission violated hearsay rules.	Harmless error where evidence was cumulative.
Second officer testimony about looking for Cofield admissible?	Francois objects to hearsay about looking for Cofield.	Testimony supports link to suspect.	Waived for appeal; not reversible.
Confrontation clause preservation?	Francois preserves Crawford issue to suppress evidence.	Objections were hearsay-only; Crawford not preserved.	Not preserved; Crawford argument rejected.

Belmar v. State, 279 Ga. 795, 621 S.E.2d 441 (2005) (harmless error when hearsay is cumulative of admissible evidence)
Wiggins v. State, 280 Ga. 627, 632 S.E.2d 80 (2006) (hearsay admission may be harmless when cumulative)
Hughes v. State, 290 Ga.App. 475, 659 S.E.2d 844 (2008) (admission of similar evidence without objection acceptable)
Treadwell v. State, 285 Ga. 736, 684 S.E.2d 244 (2009) (distinction between confrontation and hearsay objections)
Walton v. State, 278 Ga. 432, 603 S.E.2d 263 (2004) (preservation of confrontation clause error)