Rai v. State, 297 Ga. 472

Rai was convicted in Fulton County and sentenced to life without parole for malice murder and related offenses arising from Sparkle Reid Rai's April 2000 death.
The State argued Rai masterminded the murder due to racial/cultural disapproval of Sparkle by Rai's family and their traditional marriage expectations.
witnesses Jackson and Tatum testified Clark killed Sparkle after being recruited by him; Clark was paid $10,000 and traveled from Atlanta to execute the crime.
Money transfers totaling $400, $500, and $600 to Clark in April 2000 were traced via Western Union, linking Rai’s associates to the murder plot.
Rai’s jailhouse statements to Walmer were recorded; the State introduced evidence of Rai’s purported motive and disapproval of Sparkle, along with other corroborating evidence.
The trial court admitted certain of Sparkle’s statements to family members under the necessity hearsay exception, and the appellate court upheld these evidentiary rulings, along with jury instructions and the adequacy of Rai’s trial representation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence	Rai; insufficient corroboration of the alleged conspiracy.	State argues substantial witnesses and money transfers prove guilt beyond reasonable doubt.	Evidence sufficient to support verdicts.
Hearsay under necessity	Admission of Sparkle’s statements to family members was improper hearsay.	Statements were necessary and trustworthy under the exception.	Trial court did not abuse discretion; statements properly admitted.
Sixth Amendment; jailhouse informant	Walmer as state agent elicited Rai’s statements in violation of Massiah.	No agency; Walmer initiated contact without promises or inducements.	No Sixth Amendment violation; Walmer not a state agent.
Prior statements about parental bias	Trial allowed testimony about Ricky and Sparkle’s views reflecting Rai's bias.	Objections preserved or not preserved; statements otherwise harmless.	No reversible error; admissible or harmless given other evidence.
Effectiveness of trial counsel	Counsel failed to object to some hearsay or bias-related testimony; prejudice shown.	Counsel acted effectively; any errors were non-prejudicial or cumulative.	No deficient performance shown; no prejudice established.

Chapel v. State, 270 Ga. 151 (1998) (necessity exception for hearsay requires necessity and trustworthiness)
Vega v. State, 285 Ga. 32 (2009) (confirms standard for evaluating conflicting witness testimony)
Smith v. State, 292 Ga. 588 (2013) (jury instruction on witness credibility and conflicts)
Mallory v. State, 261 Ga. 625 (1991) (reliability of victim statements under necessity exception)
Burgan v. State, 258 Ga. 512 (1988) (jailhouse informant not automatically a government agent)