Jackson v. State, 294 Ga. 34

On Oct. 10, 2008, Anastasia Jackson traveled to Atlanta to buy cocaine from Alton Sewell; a drug meeting at a gas station was followed by an armed robbery and shooting in which Sewell died.
Jackson was at the scene, entered Sewell’s truck, left in her car while two gunmen robbed Sewell and Hardy; witnesses saw a black sedan follow Jackson’s car.
Hardy (the victim) and Jackson identified Larry Kennedy as the shooter; cell-phone records placed Jackson and Kennedy near the scene and showed Jackson called Kennedy immediately after the shooting.
After the incident Jackson told Hardy she “got to eat,” later wired him money, and continued drug dealings with Kennedy.
Jackson was indicted on multiple counts, acquitted of malice murder but convicted of felony murder (and related offenses); she appealed raising challenges to jury instructions, witness-bias cross-examination limits, ineffective assistance of counsel, and sufficiency of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to instruct jury on accomplice corroboration	Jackson: court should have instructed that Hardy’s testimony required corroboration under former OCGA § 24-4-8	State: corroborating circumstantial evidence existed so instruction was unnecessary	Court: No plain error — evidence independently corroborated Hardy so no instruction required
Restriction on exploring witness bias	Jackson: prevented from fully cross-examining Hardy about potential recidivist penalties tied to pending charges	State: Hardy had no deal with prosecution; probing into speculative penalties was properly limited	Court: No error — defense could explore motive/bias and prior convictions; penalty detail excluded appropriately
Ineffective assistance of counsel (multiple acts)	Jackson: counsel failed to request corroboration charge, obtain recidivist notice, and object to alleged misstatements in closing	State: counsel’s choices were reasonable trial strategy and no prejudice shown	Court: Strickland not satisfied — performance not deficient and no reasonable probability of different outcome
Sufficiency of the evidence	Jackson: challenges overall sufficiency to support convictions	State: circumstantial and direct evidence (calls, movements, statements, payments, eyewitnesses) support verdict	Court: Evidence sufficient under Jackson v. Virginia to sustain convictions

Jackson v. Virginia, 443 U.S. 307 (establishes standard for assessing sufficiency of the evidence)
Strickland v. Washington, 466 U.S. 668 (sets two-prong test for ineffective assistance of counsel)
Davis v. Alaska, 415 U.S. 308 (rule allowing cross-examination to expose potential bias)
Hall v. State, 241 Ga. 252 (no corroboration instruction required where accomplice testimony is independently corroborated)
State v. Kelly, 290 Ga. 29 (plain-error standard for unobjected-to jury charges)