Hawkins v. State, 304 Ga. 299

In Oct. 2012 a confrontation outside an Atlanta nightclub ended when a single shot from a car fatally struck Morie Brooks as he ran away; Orlando Hawkins was tried and convicted of malice murder and related firearm offenses.
Surveillance stills and eyewitnesses placed Hawkins in the pre-shooting altercation, running to the car used in the incident, and wearing a sleeveless shirt matching the arm seen brandishing a revolver from the back passenger window.
Co-defendant James Rogers Jr. testified and identified Hawkins as the shooter; another participant (Hanad a/k/a T‑Mac) denied involvement.
Hawkins allegedly admitted to Rogers’ sister that he had shot someone; Hawkins later sent threatening Facebook messages to Rogers Jr. after Rogers cooperated.
Trial court admitted screenshots of Facebook messages authenticated by Rogers Jr.; Hawkins had received the screenshots four days before trial and moved in limine to exclude them.
Hawkins challenged (on appeal) the parties‑to‑a‑crime jury charge, the trial court’s failure to give an accomplice‑corroboration charge sua sponte, and the admission/timing of the Facebook evidence. The conviction and sentence were affirmed.

Issue	Plaintiff's Argument (Hawkins)	Defendant's Argument (State)	Held
Whether giving a parties‑to‑a‑crime instruction was error	Charge inappropriate because Hawkins disputed that others aided a shooting	Slight evidence showed joint action and coordination supporting the charge	No error; evidence supported parties charge
Whether failure to give accomplice‑corroboration charge sua sponte was plain error	Omission was plain error because Rogers Jr. was the only witness directly tying Hawkins to the shooting	Although omission was clear error, substantial independent corroboration made the omission harmless	No plain error; corroborating evidence made outcome unlikely to be affected
Whether Facebook screenshots were properly authenticated	Screenshots not properly authenticated as Hawkins’ messages	Rogers Jr. identified the account and recognized the messages/photos; circumstantial authentication sufficed	No abuse of discretion; authentication adequate for admission
Whether late disclosure of screenshots violated discovery and required exclusion	Disclosure 4 days before trial violated OCGA §17‑16‑4 and prejudiced defense	State informed defense as soon as it had the material; no bad faith and evidence was cumulative; no prejudice and no continuance sought	No abuse of discretion; exclusion unnecessary absent bad faith and prejudice

Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency‑of‑evidence standard assessing whether any rational trier of fact could convict)
Davis v. State, 269 Ga. 276 (explains minimal evidence needed to authorize a jury instruction)
Bragg v. State, 295 Ga. 676 (party liability/jury instruction precedent)
Stanbury v. State, 299 Ga. 125 (failure to give accomplice‑corroboration charge can be plain error where accomplice testimony is bedrock of conviction)
Kelly v. State, 290 Ga. 29 (sets four‑part plain‑error test for unobjected‑to charge issues)
Cotton v. State, 297 Ga. 257 (electronic communications may be authenticated circumstantially)
Cushenberry v. State, 300 Ga. 190 (discusses remedies for discovery violations and the bad‑faith/prejudice standard for exclusion)