Smith v. State, 295 Ga. 283

In Sept. 6–7, 2008, Smith attempted a BP gas-station robbery; PK Patel was shot in the leg and Justin Patel died at the scene, while the gunman was not identified by store staff.
Smith also robbed Miguel Perez at gunpoint the morning of Sept. 6, 2008, and took $143; Perez later identified Smith from a six-person photo lineup.
Police obtained a tip linking Smith to the crimes and later learned of the Freemans’ restaurant robbery after arrest warrants were issued.
Smith confessed to the Perez and Freemans robberies and to the BP shooting during a videotaped interrogation after waiving Miranda rights; ballistics linked the gun to shell casings and the bullet from Justin Patel.
The trial court admitted the confession; Smith challenged it as involuntary and attacked portions concerning a sister’s alleged involvement and the gun’s location; the court held the confession voluntary and corroborated by other evidence.
The appellate court affirmed all convictions, finding the evidence sufficient and venue established, and rejecting ineffective-assistance arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the confession voluntary and admissible?	Smith contends the interrogation used an implied incentive and coercive framing.	State argues no promise of leniency or fear of injury rendered the confession involuntary.	Confession voluntary; no OCGA 24-3-50 violation.
Should the portion of the confession about the sister be excluded as coercive?	Smith asserts this segment was coerive and tainted the gun/ballistics evidence.	State contends statements about sister were not coercive and did not render confession involuntary.	Portion admissible; no reversible error.
Is the BP shooting evidence legally sufficient, considering corroboration of the confession?	Without the confession’s gun/ballistics and corroboration, evidence may be insufficient.	Corroboration from eyewitness and ballistic evidence suffices.	Evidence corroborated confession; sufficient for guilt.
Did the State prove venue for the BP shooting?	Venue was not properly established.	Testimony and map placement showed Chatham County context.	Venue established.
Was trial counsel ineffective for not challenging the sister-confession admissibility?	Counsel should have pursued suppression of that confession portion.	No deficient performance or prejudice shown given admissibility.	No ineffective-assistance merit.

Turner v. State, 287 Ga. 793 (2010) (voluntariness standard for confessions; credibility upheld on review)
Merritt v. State, 292 Ga. 327 (2013) (corroboration can sustain a conviction when corroboration exists)
Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency of evidence standard)
Smith v. State, 291 Ga. App. 535 (2008) (application of voluntariness and related considerations)
Griffin v. State, 257 Ga. App. 167 (2002) (no involuntariness where police statements do not amount to torture)
Dennis v. State, 293 Ga. 688 (2013) (promises of benefit generally must be explicit to render involuntary)
Armstrong v. State, 286 Ga. 420 (2010) (venue and evidentiary considerations in Georgia)