Hood v. State
311 Ga. 855
Ga.2021Background
- Appellant Jamie Hood was tried after admitting to and being linked to two separate homicide events: the December 2010 murder of Kenneth Omari Wray and the March 2011 shootings of Athens‑Clarke County officers (including Officer Elmer Christian).
- During a March 2011 manhunt Hood was captured after staying at a Creekstone home where several occupants (including Quintin Riden) recorded and later testified about Hood’s incriminating statements; Hood also made recorded admissions to others and to investigators.
- Ballistics testing tied a .40‑caliber shell casing found in Hood’s car to the gun that killed Wray; other evidence included multiple witnesses’ testimony about Hood’s admissions and physical evidence from the crime scenes.
- Riden testified at trial; the jury learned Riden had pled guilty in federal court to drug charges and that his plea required cooperation, but the State did not disclose separate state charges against Riden that were later nolle prossed nor the extent to which Riden’s cooperation produced a downward federal sentence.
- Hood represented himself at trial (Faretta). He was convicted on 36 counts related to the murders, kidnapping, and related offenses and received life sentences; on appeal he raised (1) a Brady/Giglio claim about undisclosed impeachment material concerning Riden, (2) omission of a statutory confession‑corroboration jury instruction, (3) cumulative prejudice from those errors, (4) failure to instruct on delusional compulsion insanity, and (5) admission of testimony about family photos on Officer Christian’s patrol‑car laptop.
Issues
| Issue | Appellant's Argument | State's Argument | Held |
|---|---|---|---|
| Brady/Giglio: suppression of impeachment evidence about witness Riden | Riden had undisclosed deals/benefits (state charges nolle prossed; federal sentence reduced due to cooperation); suppression deprived Hood of material impeachment and warrants new trial for Wray murder | Jury already knew Riden pled guilty and had a cooperation obligation; additional impeachment would be cumulative and not material given the strong independent evidence | No Brady relief: even assuming suppression, no reasonable probability of a different outcome given corroborating witnesses and ballistics linking Hood to Wray’s murder |
| Failure to give statutory confession‑corroboration instruction (OCGA § 24‑8‑823) | Hood’s confessions were critical; omission was plain error likely affecting outcome | Multiple confessions to different witnesses, corroboration by other evidence (ballistics, motive), so omission could not have altered verdict | No plain error: confessions were corroborated by abundant independent evidence |
| Cumulative prejudice (Lane) | The combined effect of Brady suppression and omitted instruction requires reversal | Even combined, defects would not likely change outcome given strength of record | No cumulative prejudice: combined alleged errors not likely to affect verdict |
| Delusional compulsion insanity instruction | Hood claimed he heard his deceased brother’s voice compelling him to run and shoot; jury should have been instructed on delusional compulsion | No evidence Hood suffered from a mental disease, injury, or congenital deficiency; even his claimed delusion wouldn’t have made the shootings lawful | No plain error: no slight evidence supporting the statutory delusional‑compulsion defense |
| Admission of testimony about family photos on officer’s laptop | Testimony was irrelevant and prejudicial | Photographs helped show officer’s car was stationary (relevance to justification) | Any error harmless: Hood admitted intent to shoot, overwhelming evidence of guilt, and similar testimony was admitted without objection elsewhere |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (prosecution must disclose favorable impeachment evidence)
- Giglio v. United States, 405 U.S. 150 (impeachment deals must be disclosed; Giglio materiality standard)
- Faretta v. California, 422 U.S. 806 (right to self‑representation)
- Strickler v. Greene, 527 U.S. 263 (Brady materiality analysis where strong independent evidence exists)
- Turner v. United States, 137 S. Ct. 1885 (suppressed‑evidence review in context of entire record)
- Danforth v. Chapman, 297 Ga. 29 (suppressed impeachment material was material when it was the only evidence of confession)
- Clarke v. State, 308 Ga. 630 (plain‑error standard for omitted jury instructions)
- State v. Lane, 308 Ga. 10 (framework for considering cumulative prejudice)