Jackson v. State, 303 Ga. 487

On September 21, 2012, Curtis Jordan (a known Bloods member wearing red) was shot and killed; the victim suffered a fatal shotgun slug wound plus multiple handgun wounds.
Lavoris Jackson and co-defendant Ramel Brown were tried jointly; Brown was observed holding a shotgun and Jackson a handgun during the incident.
A witness saw both Brown and Jackson shooting; another unidentified man fired a shotgun from a passing truck. One witness initially did not name Jackson but later identified him as shooting a handgun.
Jackson was indicted on multiple counts including malice murder, felony murder alleging death by shotgun, aggravated assault, gang activity, and firearm-possession charges; jury convicted on all counts at trial.
Post-trial, felony-murder verdicts were vacated by operation of law; some sentencing adjustments and a nolle prosequi on the gang charge followed. Jackson appealed convictions.

Issue	Plaintiff's Argument (Jackson)	Defendant's Argument (State)	Held
Sufficiency of the evidence to support murder and related convictions	Evidence shows Jackson only fired a handgun; victim died from a shotgun slug, so Jackson cannot be guilty of murder by shotgun	Jackson can be convicted as a party to the crime if shared intent is proven or reasonably inferred from conduct	Court held evidence was sufficient to convict Jackson as a party to the crimes under OCGA § 16-2-20; jury could infer shared intent and convict despite another person firing the fatal shotgun shot
Omission of a jury instruction on proximate causation / plain error review	Trial court erred by not instructing jury on proximate causation when indictment alleged death by shotgun	Jury was properly instructed on murder, felony murder, and party-to-a-crime principles; proximate-cause instruction not required for no plain error	No plain error: instructions taken as a whole adequately addressed causation and party liability, so failure to give a separate proximate-causation charge did not require reversal

Grant v. State, 298 Ga. 835 (2016) (shared criminal intent may be inferred from a defendant's conduct)
Jones v. State, 292 Ga. 656 (2013) (persons concerned in commission of a crime may be convicted even if another fired the fatal shot)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)
Flournoy v. State, 294 Ga. 741 (2014) (no separate proximate-causation instruction required when party-to-a-crime and causation are otherwise instructed)
Pennie v. State, 292 Ga. 249 (2013) (jury instruction sufficiency judged on charges read as a whole)
Alvelo v. State, 290 Ga. 609 (2012) (plain-error standard for unpreserved jury-charge errors)
Sapp v. State, 290 Ga. 247 (2011) (court reviews jury instructions in context of the entire charge)
Williams v. State, 298 Ga. 208 (2015) (addresses party liability and instruction sufficiency)
Brown v. State, 300 Ga. 446 (2017) (companion decision upholding co-defendant Brown's convictions)