Frazier v. State, 308 Ga. 450

On Feb. 7, 2016, a shootout at Kaolin Park (Sandersville) left Quenterious Griner dead from a .40‑caliber bullet later matched to a gun given by D’Andrious Brown.
Michael Antonio Frazier, Jr. (Appellant) was with Mardriquez Harper, Griner, and Brandon Seals earlier that day; a phone call overheard by witnesses referenced a planned drug meeting, guns, and a potential robbery/violence.
At the park, Harper’s group (including armed members) approached Brown’s car; Seals kicked open a restroom door where Brown’s associates were hiding, shots were fired, Griner was fatally shot, and others were wounded.
Appellant initially told investigators he was uninvolved, later admitted he went to the park with Harper’s group, knew some were armed, and described events consistent with an anticipated drug‑related robbery; he fled the scene and briefly evaded police.
At trial Appellant was convicted as a party to felony murder (based on attempted armed robbery) and of possessing a firearm during a felony; he appealed solely on the ground that the evidence was legally insufficient.

Issue	Appellant's Argument	State's Argument	Held
Whether the evidence was sufficient to convict Frazier as a party to felony murder and firearm possession	Frazier argued the proof was insufficient — he did not fire the fatal shot and was merely present; circumstantial evidence did not exclude reasonable innocence	The State argued the evidence (admissions, presence with armed accomplices, overheard threats, conduct before/during/after the incident, flight, and post‑shooting statements) showed he intentionally aided/abeted or was a party to the underlying felony making the death foreseeable	Court affirmed: viewed in light most favorable to the verdict, the evidence was sufficient to convict him as a party to the attempted armed robbery (proximate cause of felony murder) and to the firearm offense; circumstantial evidence met Georgia law

Jackson v. Virginia, 443 U.S. 307 (1979) (establishes federal due‑process standard for sufficiency review)
Mims v. State, 304 Ga. 851 (2019) (Georgia application of sufficiency review standard)
Clark v. State, 307 Ga. 537 (2019) (reinforces standard and appellate review scope)
Parks v. State, 304 Ga. 313 (2018) (criminal intent may be inferred from presence, companionship, and conduct)
Broxton v. State, 306 Ga. 127 (2019) (party‑to‑crime principles where defendant did not fire fatal shot)
Bryant v. State, 296 Ga. 456 (2015) (party liability when defendant does not personally commit the fatal act)
State v. Jackson, 287 Ga. 646 (2010) (proximate causation and foreseeability in felony murder when accomplice is killed)
Robinson v. State, 298 Ga. 455 (2016) (fatal shooting of accomplice by victim can be foreseeable in attempted armed robbery)
Graves v. State, 306 Ga. 485 (2019) (application of OCGA § 24‑14‑6; jury resolves alternative hypotheses)
Muckle v. State, 302 Ga. 675 (2017) (sufficiency of circumstantial evidence review)
Hill v. State, 297 Ga. 675 (2015) (party liability and circumstantial‑evidence sufficiency)