Rhodes v. State, 299 Ga. 367

On Feb. 3, 1998, Frederick and Yong‑Suk Walker were found shot to death in their Evans, GA home; Rhodes and co‑defendants Jimmie Lee Rhodes and David Easterling were implicated after a break‑in and robbery.
Rhodes was indicted on multiple counts including malice murder, felony murder, armed robbery, burglary, and firearm offenses; tried in Feb. 2004, convicted on all counts, and sentenced to consecutive life terms (death not imposed).
Co‑defendant Jimmie Lee was earlier convicted and sentenced to life without parole; Easterling pled guilty to murders and other offenses and testified for the State at Rhodes’s trial.
Russell Sharpe, an inmate who met Rhodes pretrial, also testified for the State recounting admissions Rhodes allegedly made and sought a deal for cooperating with prosecutors.
Rhodes moved for a new trial claiming Brady/Giglio violations: the State allegedly failed to disclose deals or promises made to Easterling and Sharpe that would impeach their credibility.
The trial court denied the motion for new trial; the Georgia Supreme Court affirmed, finding no suppressed Brady/Giglio material and no reasonable probability of a different outcome.

Issue	Rhodes's Argument	State's Argument	Held
Whether the State suppressed impeachment evidence (deals/promises) with key witnesses in violation of Brady/Giglio	The State failed to disclose terms/extent of alleged deals with Easterling and Sharpe; nondisclosure deprived Rhodes of exculpatory/impeachment evidence	No undisclosed deals existed regarding pending charges; plea terms were public; any promises were either non‑existent or known/attackable at trial	No Brady/Giglio violation: Rhodes failed to prove undisclosed agreements existed and cannot show a reasonable probability of a different verdict if additional impeachment had been disclosed
Whether impeachment value of any undisclosed agreement would have affected the verdict	Impeachment of key witnesses would have undermined their credibility and changed the jury’s verdict	Witnesses’ motives and deals were exposed at trial through cross‑examination and public records; additional detail would not likely change outcome	Rhodes cannot show reasonable probability that additional impeachment evidence would have altered the verdict

Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose exculpatory evidence material to guilt or punishment)
Giglio v. United States, 405 U.S. 150 (1972) (impeachment agreements with witnesses must be disclosed; failure to do so can warrant reversal)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence — whether any rational trier of fact could have found guilt beyond a reasonable doubt)
Brannon v. State, 298 Ga. 601 (2016) (State must reveal agreements with witnesses on pending charges; defendant must show reasonable probability of a different outcome)
Younger v. State, 288 Ga. 195 (2010) (discusses Giglio/Brady disclosure obligations)
Hulett v. State, 296 Ga. 49 (2014) (procedural note regarding vacatur of felony murder counts by operation of law)