Price v. State, 316 Ga. 400

On October 13, 2016, two men (Dexter Covin and L. C. Tumblin Jr.) were shot at a residence; both later died (Tumblin from infection related to his wounds). Tumblin, at the scene, told officers the shooter was "Travis Price."
Eyewitness Fred Armstrong saw a black Toyota Camry; he observed Appellant Trevis (Travis) Price and Covin together in the Camry, then saw Price exit behind Covin and shoot him, and heard shots fired toward the porch and nearby vehicles.
Police searched Price’s room and recovered individually bagged cocaine (~9 grams), marijuana, a scale, and razor blades; an officer testified the cocaine was packaged for distribution.
Phone records and text messages showed calls and texts between Covin and Price in the days before the shooting, including texts arranging the purchase of "clean" cocaine for $1,100 shortly before the incident.
Price turned himself in, admitted ownership of the drugs but denied involvement in the shootings; he also identified multiple names and two phone numbers he used.
A Dougherty County jury convicted Price of malice murder (two counts) and related offenses; the trial court denied his motion to sever the drug-possession count and his motion for new trial was denied; Price appealed to the Supreme Court of Georgia.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for malice murder	Price: inconsistencies (no bodycam video of Tumblin ID, no hospital interview testimony), Armstrong could not identify Price at trial, investigative flaws — thus evidence insufficient	State: Tumblin’s on-scene identification, Armstrong’s eyewitness account of the shooting, drug evidence, and phone/text records tying Price to Covin supported a rational verdict	Affirmed — viewing evidence in the light most favorable to the jury, there was competent evidence to support malice murder; inconsistencies go to weight/credibility, not sufficiency (Jackson standard)
Denial of motion to sever Count 11 (possession with intent to distribute)	Price: joinder of the drug count with the murder charges was highly prejudicial and impeded fair consideration of the murder charges	State: offenses arose from the same course of conduct and drug-dealing context; evidence was straightforward and not likely to confuse jury	Affirmed — trial court did not abuse discretion; severance not required where charges arise from same conduct/continuing scheme and no showing of jury confusion or unfair prejudice

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency-of-evidence review)
Malcolm v. State, 263 Ga. 369 (duplicate felony-murder counts may be vacated by operation of law)
Yarn v. State, 305 Ga. 421 (jury resolves credibility and conflicts in testimony)
Roberts v. State, 305 Ga. 257 (verdict upheld if competent evidence supports each fact, even if contradicted)
Lowe v. State, 314 Ga. 788 (severance doctrine: same-character joinder vs same-conduct joinder)
Carson v. State, 308 Ga. 761 (trial court discretion in severance; fairness inquiry required)
Rodriguez v. State, 309 Ga. 542 (assessing whether jury can distinguish evidence; severance not warranted where offenses are related)
Jackson v. State, 314 Ga. 82 (application of severance standards where crimes arose from a continuing course of conduct)