Mangram v. State, 817 S.E.2d 682

Background

On May 25, 2012, Untavious Gillard was shot multiple times; his body was later found; Mangram (age 17) was arrested and tried for malice murder and related offenses alongside co-defendants White and Lang.
Witnesses and surveillance showed Mangram, White, and Lang together soon after the shooting; a 911 caller heard shots and saw persons matching descriptions of Mangram and Lang get into a silver/gray sedan.
White testified as a co-defendant that Mangram shot Gillard; she later cooperated with police and pled guilty to concealing a death.
Surveillance at a Brunswick car wash captured the three arriving ~31 minutes after the 911 call and cleaning the car interior; investigators later found bullet holes and Gillard's blood/DNA in Lang’s car.
Mangram and the others removed clothing, a shoe, guns, and other items from the back seat; Mangram later told others Gillard had “played with [his] people.”
At trial Mangram moved for directed verdict (insufficient corroboration of accomplice testimony) and for mistrial after a witness said she’d heard a rumor that Gillard had a bounty on his head; the court denied both motions and Mangram was convicted and sentenced to life plus consecutive terms.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether White's testimony (accomplice) was sufficiently corroborated	State: independent circumstantial evidence (911 caller, surveillance, car-cleaning, blood/DNA) corroborates White	Mangram: White is an accomplice; her testimony required corroboration and was insufficient	Held: Corroboration was sufficient under OCGA §24-14-8; evidence permitted jury to convict beyond reasonable doubt
Whether the denial of directed verdict (Jackson sufficiency) was proper	State: viewing evidence in light most favorable to verdict, a rational juror could find guilt beyond reasonable doubt	Mangram: evidence insufficient to support malice murder and convictions	Held: Applying Jackson v. Virginia standard, evidence was legally sufficient; directed verdict properly denied
Whether trial court erred by denying mistrial after testimony about bounty rumor	Mangram: rumor testimony was inadmissible hearsay, irrelevant absent evidence defendants knew of it, and required mistrial	State: trial court sustained objection and gave curative instruction; evidence of malice independent of rumor	Held: Denial of mistrial not an abuse of discretion; jury presumed to follow curative instruction and other evidence supported malice
Whether rumor evidence was necessary to prove malice/motive	Mangram: equates rumor with essential proof of malice/motive	State: motive not essential element of malice murder; other evidence established malice	Held: Motive not required; multiple shots, circumstances, and defendant’s statements supported malice without rumor evidence

Key Cases Cited

Crawford v. State, 294 Ga. 898 (2014) (accomplice testimony requires corroboration under Georgia law)
Robinson v. State, 303 Ga. 321 (2018) (corroborating evidence may be slight and circumstantial)
Parks v. State, 302 Ga. 345 (2017) (corroboration need not alone warrant conviction but must independently connect defendant to crime)
Cisneros v. State, 299 Ga. 841 (2016) (defendant’s pre- and post-offense conduct may 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) (Georgia applies Jackson standard to directed verdict denial)
Johnson v. State, 302 Ga. 774 (2018) (mistrial is within trial court’s discretion; reversal only if essential to preserve fair trial)
Cannon v. State, 302 Ga. 327 (2017) (presumption that jury follows curative instruction)
Moran v. State, 302 Ga. 162 (2017) (malice may be formed instantly; proof may be deliberate intent or abandoned and malignant heart)
Coleman v. State, 301 Ga. 720 (2017) (curative instruction can cure inadmissible testimony where other evidence of guilt is strong)