Mills v. State, 320 Ga. 457

Roger Tashawn Mills was convicted of felony murder and other related offenses after a retrial stemming from the 2017 shooting death of Masuto Garrett.
Mills' prior convictions were reversed on appeal due to the improper removal of a holdout juror; after retrial, Mills was found guilty of felony murder, aggravated assault, and possession of a firearm during the commission of a felony.
The incident occurred at Stanley Yates’s house, known locally as a neighborhood hangout. The dispute involved Mills, his co-defendant Moses Bolar, and victim Garrett, following a verbal altercation with gang undertones.
At trial, the State argued the shooting was gang-related retaliation, presenting evidence of gang affiliations and prior group assaults involving Mills and Bolar.
Mills claimed self-defense, asserting he reasonably feared for his and Bolar’s safety, and challenged the admission of other-acts evidence at trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence (justification defense)	Mills argued the State failed to disprove he acted in self-defense or defense of another beyond a reasonable doubt.	State contended that the evidence, including testimony and physical evidence, disproved self-defense.	Affirmed: Sufficient evidence supported the jury’s rejection of the justification defense.
Admission of other-acts evidence under Rule 404(b)	Mills argued it was plain error to admit evidence of a prior assault.	State argued the evidence was admissible to show motive and gang affiliation.	Affirmed: Evidence was properly admitted because it was relevant to motive and its probative value outweighed unfair prejudice.

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
Birdow v. State, 305 Ga. 48 (State's burden to disprove justification defense when presented)
Russell v. State, 319 Ga. 556 (jury’s prerogative to accept or reject a justification defense)
Kirby v. State, 304 Ga. 472 (requirements for admitting other-acts evidence under Rule 404(b))
Lee v. State, 318 Ga. 412 (reviewing Rule 403 issues, favoring admissibility)