Huff v. State, 300 Ga. 807

Background

Huff was convicted of malice murder, aggravated assault, and felony firearm for the October 5, 2012 shooting death of Graham Sisk; co-defendants Starr and Turner later pled to lesser charges and testified for the State.
Facts viewed in the light most favorable to the verdict: Huff recruited Turner, Starr, and Haygood to move belongings; Turner attempted a drug sale using Huff’s pickup; the buyer drove off; a high-speed pursuit followed with Turner ramming the buyer’s car.
Huff (driving an SUV) pulled into oncoming traffic and stopped near the victim; Starr and Haygood exited the SUV and Starr shot the victim through the passenger window, killing him; pills recovered were over-the-counter allergy medicine.
Huff gave a statement acknowledging he was driving the SUV; defense witnesses (including Turner and Haygood) offered competing accounts attempting to minimize Huff’s knowledge or responsibility for the shooting.
At trial, the principal testimonial link tying Huff to the shooting came from accomplice testimony (Starr), but the state also introduced Huff’s statements and eyewitness/surveillance evidence of Huff’s conduct before, during, and after the shooting.
Huff moved for a new trial based on Starr’s post-trial recantation and argued on appeal insufficiency of corroboration, instructional errors (accomplice corroboration and coercion), and ineffective assistance of counsel. The trial court denied the motion; the Supreme Court of Georgia affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence / accomplice corroboration	Huff: Starr was an accomplice and his testimony was the only direct evidence linking Huff; thus convictions lack required corroboration	State: Huff’s statements, eyewitnesses, surveillance, and testimony from other participants corroborated Starr; jury could find guilt beyond a reasonable doubt	Affirmed — evidence (including circumstantial) sufficiently corroborated accomplice testimony; Jackson v. Virginia standard met
Failure to instruct jury that accomplice testimony requires corroboration	Huff: Trial court erred by not giving an accomplice corroboration instruction	State: No request or objection below; omission was not plain error given corroborating evidence and the court’s other instructions	Affirmed — omission was not plain error; unlike Stanbury, here the charge was incomplete rather than affirmatively misleading and evidence was strong
Failure to charge that coercion is not a defense to murder	Huff: Court should have instructed that coercion isn’t a defense to murder to undercut Starr’s claimed coercion	State: No request/objection; coercion charge was not tailored to facts and was irrelevant to Huff’s defense theory	Affirmed — omission not plain error; coercion instruction not responsive to the evidence presented
Ineffective assistance of counsel for not seeking corroboration or coercion charges or a directed verdict	Huff: Trial counsel was deficient and prejudice resulted from failing to request these charges/moves	State: Counsel pursued a strategy to show Huff lacked knowledge and to avoid labeling Starr an accomplice; tactical choices were reasonable; no reasonable probability of a different outcome	Affirmed — counsel’s strategy was reasonable; Huff failed to show deficient performance or prejudice under Strickland

Key Cases Cited

Bradford v. State, 261 Ga. 833 (slight corroboration of accomplice testimony is sufficient)
Berry v. State, 248 Ga. 430 (corroboration may be circumstantial and include pre/post conduct)
Herbert v. State, 288 Ga. 843 (one accomplice’s testimony may corroborate another)
Handley v. State, 289 Ga. 786 (multiple accomplices can corroborate each other even absent forensic evidence)
Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence)
Sanders v. State, 290 Ga. 637 (plain error review for unpreserved jury-charge errors)
State v. Kelly, 290 Ga. 29 (four-part plain-error framework and difficulty of satisfying it)
Stanbury v. State, 299 Ga. 125 (omission of accomplice corroboration charge can be plain error when jury effectively authorized conviction on accomplice alone)
Norwood v. State, 273 Ga. 352 (post-trial recantation generally does not warrant new trial absent clear evidence of fabrication)
Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard: deficient performance and prejudice)
Kimmelman v. Morrison, 477 U.S. 365 (ineffective assistance standards applied to counsel performance review)
Williams v. Taylor, 529 U.S. 362 (prejudice inquiry under Strickland)
McLean v. State, 297 Ga. 81 (trial tactics on jury charges are generally strategic and non-grounds for reversal)
State v. Worsley, 293 Ga. 315 (deference to trial counsel; scrutiny highly deferential)
Bradshaw v. State, 296 Ga. 650 (interpretation of corroboration statute carried forward)
Malcolm v. State, 263 Ga. 369 (merger principles for convictions)
Fisher v. State, 299 Ga. 478 (similar accomplice-instruction error context)