Odle v. State, 331 Ga. App. 146

On Sept. 2, 2011 a masked gunman robbed a bank teller line; multiple tellers and customers testified they were ordered to the floor and feared for their safety.
Surveillance video depicted the robber wearing a white tee, blue jeans, and a tan cap; a tracking device placed in the stolen bag led police to a vehicle and then to a wooded area.
Police pursuit led to the detention of driver D.H. and the capture of Odie wearing a white tank top and blue shorts; clothing matching the video (jeans, tan cap, white tees) and the bag with cash and a tracker were found near the vehicle and in the woods.
D.H. pleaded guilty and testified that he drove Odie from the bank, that Odie removed outer shirts, tossed the money bag, changed clothes en route, and fled the vehicle; cell records showed a text from Odie to D.H. the morning of the robbery.
Odie was convicted by a jury of three counts of armed robbery, nine counts each of aggravated assault and false imprisonment (for various tellers/customers), and two counts of felony firearm possession; he appealed the denial of his motion for new trial.
On appeal Odie argued (1) insufficient evidence because the prosecution relied on an accomplice (D.H.) without adequate corroboration under OCGA § 24-14-8, and (2) ineffective assistance because counsel failed to object to testimony by a customer (H.R.) about her husband’s (M.R.) reaction.

Issue	Odie's Argument	State's Argument	Held
Sufficiency of the evidence / accomplice corroboration	D.H. was an accomplice and his testimony was uncorroborated; convictions therefore insufficient under OCGA § 24-14-8	Evidence beyond D.H. (surveillance, clothing, recovered money & tracker, flight, clothing found in woods, cell records, multiple eyewitnesses) corroborated guilt	Affirmed: viewing evidence favorably to prosecution, a rational jury could find guilt; corroboration requirement not outcome-determinative here
Ineffective assistance for failure to object to H.R.’s testimony about her husband	Counsel should have objected to hearsay/speculation when H.R. testified M.R. "felt the same way" (not free to leave)	H.R.’s testimony was not hearsay (not recounting M.R.’s out-of-court statement) and victim state of mind may be inferred from conduct; no prejudice shown	Affirmed: counsel not shown to be deficient or to have prejudiced outcome

Stills v. State, 327 Ga. App. 767 (discusses corroboration of accomplice testimony)
Styles v. State, 329 Ga. App. 143 (corroboration and sufficiency standards)
Lindsey v. State, 295 Ga. 343 (standards for reviewing accomplice testimony corroboration)
Crawford v. State, 294 Ga. 898 (prior treatment of accomplice corroboration under predecessor statute)
Colzie v. State, 289 Ga. 120 (Strickland standard application in Georgia)
Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard)
Smith v. State, 284 Ga. 304 (prejudice requirement under ineffective assistance review)