Norman v. State, 298 Ga. 344

Victim Monique Flores-Owens was found dead in a hotel room registered to Edward Norman; cause of death was manual strangulation.
Norman gave an hour-long recorded statement admitting he killed Flores-Owens, stayed with the body for about two days, and engaged in sexual acts with the corpse. He also said he covered her with a sheet and placed two Bibles on her body before leaving.
Hotel guests testified they heard a struggle, saw Norman and a naked woman when they knocked, and observed Norman slam the door and act aggressively—corroborating parts of his confession.
Physical and medical evidence (condition of room, time body remained, injuries consistent with manual strangulation) matched Norman’s account.
Norman was convicted of malice murder and necrophilia; he challenged the sufficiency of evidence for necrophilia and portions of the prosecutor’s closing argument. He did not testify; trial court denied his motions and he appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of necrophilia evidence	State: confession plus corroborating facts supported conviction	Norman: confession was the only evidence and was uncorroborated and equivocal	Affirmed — confession was corroborated by independent facts; jury could convict beyond reasonable doubt
Reliability/clarity of necrophilia confession	State: defendant repeatedly and spontaneously admitted postmortem sexual acts	Norman: statements were vague, elusive, contradictory	Affirmed — confession was direct ("Yes" when asked) and repeated; sufficient when viewed with corroboration
Use of uncorroborated confession under Georgia law	State: confession may be used if corroborated in any particular	Norman: relied solely on confession which must not be the only evidence	Affirmed — Georgia law requires corroboration in any particular; present here
Prosecutor's closing argument	State: closing was proper	Norman: prosecutor made improper remarks	Not reviewed — defendant failed to object at trial, waiving review on appeal

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence)
Moore v. State, 285 Ga. 157 (2009) (confession need only be corroborated in any particular)
Merritt v. State, 292 Ga. 327 (2013) (confession may be considered with other facts not wholly independent of it)
Vega v. State, 285 Ga. 32 (2009) (jury decides witness credibility and resolves conflicts)
Lewis v. State, 296 Ga. 259 (2014) (same standard applies to directed-verdict/directed-acquittal review)
Scott v. State, 290 Ga. 883 (2012) (failure to object to closing argument waives appellate review)