Head v. State, 316 Ga. 406

In November 2006 a group organized at Head’s house to rob a tattoo artist (the victim, Dwight Smith); Head allegedly led the planning and assigned roles.
Michael (an accomplice) testified Head gave him a nickel-plated .45 and that Michael and Sutton executed the robbery at Smith’s home; a struggle ensued and Smith was shot and later died.
Jarboe, Hunt, and phone records showed contacts between numbers tied to Jarboe/Hunt and a MetroPCS number (3159) used to schedule a tattoo appointment; Hunt admitted using and later changing the 3159 number.
A photo lineup identified Head and Hunt; when arrested a .45 matching the description fell from Head’s waistband.
Head was convicted of felony murder and related counts (acquitted of malice murder); he appealed arguing (1) accomplice testimony was insufficiently corroborated under former OCGA § 24-4-8 and (2) the trial court erred in admitting the detective’s hearsay testimony identifying Head as the user of the 3159 number.
The Supreme Court of Georgia affirmed: it found adequate corroboration of the accomplice’s testimony and, assuming error in admitting the detective’s out-of-court identification, held any error was harmless.

Issue	Plaintiff's Argument (Head)	Defendant's Argument (State)	Held
Sufficiency of corroboration under former OCGA § 24-4-8	Michael was an accomplice; his testimony alone was insufficient to convict Head.	Multiple independent items (Jarboe’s statement, Hunt’s admissions about the 3159 number/change, phone records, lineup ID, firearm found on Head) provided the slight independent corroboration required.	Corroboration was sufficient; a rational jury could find Head guilty beyond a reasonable doubt. Convictions affirmed.
Admissibility of detective’s testimony identifying the 3159 number as Head’s (hearsay)	The detective’s statement amounted to inadmissible hearsay and should have been excluded.	Even if inadmissible, the testimony was cumulative of other evidence (Hunt’s admissions, phone activity, lineup, gun) and therefore harmless.	Assuming error, it was harmless beyond a reasonable probability it affected the verdict; holdings affirmed.

Malcolm v. State, 263 Ga. 369 (court on merger/vacatur of counts) (1993) (on operation of law vacating merged counts)
Styles v. State, 309 Ga. 463 (corroboration need not be strong; can be slight and circumstantial) (2020)
Doyle v. State, 307 Ga. 609 (corroborating evidence must independently connect defendant to crime or infer guilt) (2020)
Thomas v. State, 311 Ga. 407 (accomplice testimony alone meets federal due process; corroboration for state rule) (2021)
Barber v. State, 314 Ga. 759 (only slight corroboration required to support accomplice testimony) (2022)
Pritchett v. State, 314 Ga. 767 (harmless-error test for evidentiary mistakes; review de novo weighing evidence) (2022)
Lyons v. State, 309 Ga. 15 (harmless-error standard: highly probable the error did not contribute to verdict) (2020)