Henderson v. State, 310 Ga. 708

On July 4, 2016 Timothy Hill was shot at a gas-station convenience store; surveillance video showed Aquillous Henderson enter with his hands in his waistband, argue, and then turn in the doorway and shoot Hill from behind; Hill died from the wound.
Henderson initially denied being at the scene, but after detectives confronted him with the video he gave recorded and written statements admitting presence and (at trial) admitting he shot Hill, claiming self‑defense.
A DeKalb County grand jury indicted Henderson for malice murder, felony murder, aggravated assault, and possession of a firearm during commission of a felony; a jury convicted him on all counts and he was sentenced to life without parole for malice murder plus consecutive five years for the firearms count.
Henderson appealed, challenging (1) the denial of his motion to suppress his custodial statement (arguing detectives induced a “hope of benefit”) and (2) the trial court’s exclusion of his testimony that Hill said he had “been to prison,” as relevant to justification and perceived fear.
The Supreme Court of Georgia reviewed sufficiency of the evidence (though not contested), the voluntariness/admissibility of the custodial statement, and the exclusion of the brief contested testimony, and affirmed the convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Henderson did not challenge sufficiency on appeal	State: evidence was sufficient	Court sua sponte reviewed and held evidence sufficient to support convictions
Suppression of custodial statement	Detectives’ statements that he could “help yourself” created a hope of benefit making confession involuntary	Statements were exhortatory, not promises of reduced charges or sentence; Miranda waiver valid	Court held statements did not create a proscribed hope of benefit and admitted the statement
Exclusion of testimony that Hill said he had “been to prison”	Testimony was relevant to justification and reasonableness of fear	Statement was inadmissible character evidence and cumulative	Court sustained objection (strike) and ruled any error harmless given cumulative threatening statements and strong evidence of guilt

Jackson v. Virginia, 443 U.S. 307 (standard for reviewing legal sufficiency of the evidence)
Miranda v. Arizona, 384 U.S. 436 (Miranda warnings and waiver requirement)
Jackson v. Denno, 378 U.S. 368 (procedure for determining voluntariness of confessions)
Perez v. State, 309 Ga. 687 (telling suspect he can “help himself” is not necessarily a promise of benefit)
Reed v. State, 307 Ga. 527 (exhortations to tell the truth do not render statements involuntary)
Keller v. State, 308 Ga. 492 (exclusion of evidence harmless when guilt strongly supported)
Mitchell v. State, 293 Ga. 1 (erroneous exclusion may be harmless when evidence is cumulative)