Nations v. State, 303 Ga. 221

On June 20, 2012, Jonathan Nations led Bobby Swint and Kenyatta Moss to a secluded location, shot Swint (killing him) and shot Moss while Moss fled; Moss’s pockets and car were taken and later found stripped. Video of the incident and eyewitness testimony were introduced at trial.
Nations was indicted on multiple counts including malice murder, felony murder, armed robbery, hijacking a motor vehicle, aggravated assault, and firearms offenses; tried June 24–30, 2014, convicted on remaining counts and sentenced to life without parole plus additional consecutive terms.
Nations testified and admitted the shootings but claimed self-defense, alleging victims pulled guns; police found no weapons on the victims and evidence showed victims were shot from behind.
Before trial Nations’ counsel withdrew a motion in limine seeking to exclude evidence of prior convictions; at trial the State presented testimony about a September 2006 armed robbery and introduced a certified copy of Nations’ 2007 guilty plea for aggravated assault arising from that robbery. Defense did not object at trial.
Nations appealed solely arguing the trial court erred by admitting evidence of the 2006 robbery; the Court reviewed only for plain error under OCGA § 24-1-103(d) because Nations failed to contemporaneously object.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of prior armed robbery evidence	Nations argued the 2006 robbery evidence was inadmissible and prejudicial under OCGA § 24-4-404(b)	State argued evidence was admissible for impeachment and other-crimes purposes; Nations withdrew the motion in limine and did not timely object	Court found no plain error: Nations cannot show the admission affected substantial rights given strong testimonial and physical evidence of guilt, so admission did not warrant reversal
Waiver / Plain-error review standard	Nations contended withdrawal of the motion in limine did not waive appellate review of the claim	State contended Nations waived the objection by withdrawing the motion and failing to object at trial	Court applied the Kelly plain-error framework, treated issue under plain error review, and concluded Nations failed the prongs (no effect on outcome); affirmed

Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency-of-the-evidence standard under federal constitutional review)
State v. Kelly, 290 Ga. 29 (plain error review framework in Georgia)
Bradshaw v. State, 296 Ga. 650 (other-crimes evidence standards and abuse-of-discretion review)
Crayton v. State, 298 Ga. 792 (holding that admission of certain evidence must affect substantial rights to constitute plain error)
Faust v. State, 302 Ga. 211 (discussing waiver by withdrawing motions in limine)
Dixon v. State, 302 Ga. 691 (procedural note on merger of convictions and sentencing issues)