Mangram v. State, 304 Ga. 213

On May 25, 2012, Untavious Gillard was shot and later died; DayQuan Mangram (age 17) was indicted alongside Shaquilla White and Rena Lang. White later pled guilty to concealing a death; Mangram and Lang were tried jointly.
White testified that Mangram shot Gillard in the back seat of a car; after the shooting Mangram dragged Gillard from the vehicle, ordered Lang to take items from his pockets, and removed Gillard’s shoe because Mangram’s fingerprints were visible.
Lang and White drove Mangram to a car wash about 31 minutes after a 911 caller reported gunshots; surveillance video showed the three arriving together and Mangram helping thoroughly clean the car interior and remove items (later containing Gillard’s blood and bullet holes).
Gillard’s body was found days later; autopsy showed multiple gunshot wounds to the head, neck, and an arm/hand. Investigators matched Gillard by fingerprints.
Mangram moved for a directed verdict arguing insufficient corroboration of White’s accomplice testimony; he also sought a mistrial after a witness (Gillard’s grandmother) testified she had heard a rumor of a bounty on Gillard’s head (objection sustained; jury instructed to disregard).
The jury convicted Mangram of malice murder and related offenses; the trial court denied his post-trial motions and the Georgia Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether White’s accomplice testimony was sufficiently corroborated	White’s testimony should support conviction; State: corroboration exists	Mangram: White’s testimony lacked independent corroboration so directed verdict required	Court: sufficiency standard met—surveillance, 911 call, timing, cleanup, and physical evidence corroborated White
Whether denial of mistrial was error after inadmissible rumor testimony	Mangram: grandmother’s bounty rumor was hearsay and prejudicial; mistrial required	State: objection sustained and jury instructed to disregard; other evidence of malice existed	Court: curative instruction sufficient; no prejudice requiring mistrial; conviction stands

Crawford v. State, 294 Ga. 898 (2014) (accomplice testimony requires corroboration under OCGA § 24-14-8)
Robinson v. State, 303 Ga. 321 (2018) (corroborating evidence may be slight and circumstantial)
Parks v. State, 302 Ga. 345 (2017) (corroboration need only independently connect defendant to crime or allow inference of guilt)
Cisneros v. State, 299 Ga. 841 (2016) (conduct before and after crime can support inference of participation)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence)
Blackmon v. State, 300 Ga. 35 (2016) (applying Jackson standard on directed verdict review)
State v. Cash, 302 Ga. 587 (2017) (jury credibility and weight of evidence reserved to jury)
Pittman v. State, 300 Ga. 894 (2017) (sufficiency review principles reaffirmed)
Johnson v. State, 302 Ga. 774 (2018) (mistrial lies within trial court’s discretion)
Cannon v. State, 302 Ga. 327 (2017) (presumption jury follows curative instruction)
Moran v. State, 302 Ga. 162 (2017) (malice may be formed instantaneously; alternatives for proving malice)
Coleman v. State, 301 Ga. 720 (2017) (curative instruction can cure improper testimony absent prejudice)
Romer v. State, 293 Ga. 339 (2013) (motive not an essential element of malice murder)
Culpepper v. State, 289 Ga. 736 (2011) (merger and vacatur principles for related counts)