ROSS v. the STATE., 343 Ga. App. 810

Deandre Ross was convicted by a jury of two counts of aggravated assault and two counts of possession of a firearm during the commission of a felony arising from a drug-sale-turned-robbery/shooting.
Key witness testimony linking Ross to brandishing/firing weapons came from Myron Glenn (property owner) and Charles Holmes (buyer), both of whom participated in the drug transaction and thus could be viewed as accomplices.
Physical and forensic evidence did not directly link Ross to the firearms used: different 9mm casings indicated multiple 9mm guns fired; recovered revolvers were .22 and .32 calibers and did not tie to Ross; no residue or fingerprint tests connected Ross or Dukes to the weapons.
The trial court instructed jurors that the testimony of a single witness, if believed, is generally sufficient to establish a fact and did not give the statutory accomplice-corroboration instruction required by OCGA § 24-14-8.
Ross did not request the accomplice-corroboration charge at trial; he raised it on appeal and argued the omission was plain error because the only evidence connecting him to the charged offenses was accomplice testimony.
The Court of Appeals found the failure to charge accomplice corroboration was clear error that affected Ross’s substantial rights and reversed his convictions.

Issue	Ross's Argument	State's Argument	Held
Whether the trial court’s failure to instruct the jury that accomplice testimony must be corroborated (OCGA § 24-14-8) is plain error	The omission was plain error because the only evidence linking Ross to the assaults and firearm counts was testimony from potential accomplices (Glenn and Holmes); a corroboration charge could have produced acquittal	The corroboration instruction was unnecessary because multiple accomplices testified and one accomplice’s testimony may be corroborated by another; moreover, sufficiency of evidence supported conviction	Reversed: omission was clear error, affected substantial rights, and could have led the jury to convict on uncorroborated accomplice testimony; reversal required

Huff v. State, 300 Ga. 807 (discussing standards for viewing evidence in favor of the verdict)
Jackson v. Virginia, 443 U.S. 307 (establishing the reasonable-viewing standard for sufficiency of the evidence)
Lyman v. State, 301 Ga. 312 (explaining plain-error review for failure to give accomplice corroboration instruction)
Hamm v. State, 294 Ga. 791 (discussing accomplice corroboration and harmless-error analysis)
Stanbury v. State, 299 Ga. 125 (holding failure to give accomplice instruction is clear error)
Selvidge v. State, 252 Ga. 243 (explaining that co-conspirator testimony warrants the same caution as accomplice testimony)
Fisher v. State, 299 Ga. 478 (addressing when accomplice testimony may be corroborated and related jury-charge issues)