Jackson v. State
289 Ga. 798
Ga.2011Background
- Appellant Quincy Marcel Jackson was tried for multiple felonies including burglary, false imprisonment, kidnapping with bodily injury, armed robbery, aggravated assault, and malice murder of Tedla Lemma.
- The crimes occurred on November 7, 2007; December 27, 2007; and March 25, 2008, with evidence describing home invasions and a jewelry-store robbery.
- Ms. Araya and Ramone Ferguson assisted Jackson; the intruders used guns and duct tape, stole wallets, cash, and valuables, and fled in a getaway car.
- During the November 7 incident, Sirak Lemma identified a silver handgun and testified about the wallet theft; police later found the wallet in Jackson’s home in a room believed to be his.
- Cell-phone records showed exchanges between Jackson and Araya during the incidents, placing them near the locations involved.
- Tedla Lemma died from smothering with blunt-force trauma; jewelry and electronics were missing from the Lemma residence and related crime scenes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether corroboration under OCGA 24-4-8 supported the accomplice testimony | Araya’s testimony required independent corroboration. | Corroboration not sufficiently established by the wallet and cell records. | Yes; sufficient corroborating evidence independently connected Jackson to the crimes. |
Key Cases Cited
- Baines v. State, 276 Ga. 117, 575 S.E.2d 495 (2003) (corroboration required for accomplice testimony; may be circumstantial and independent)
- Johnson v. State, 288 Ga. 803, 708 S.E.2d 331 (2011) (corroboration must directly connect the defendant to the crime)
- Judkins v. State, 282 Ga. 580, 652 S.E.2d 537 (2007) (standard for evaluating sufficiency after accomplice testimony)
- Simpson v. State, 278 Ga. 336, 602 S.E.2d 617 (2004) (affirms corroboration standards and circumstantial evidence relevance)
- Wilson v. State, 306 Ga. App. 827, 703 S.E.2d 400 (2010) (addressing corroboration and circumstantial evidence in accomplice cases)
