State v. Desmond Tremaine Dowell, A21A0479

December 10, 2015: an armed robbery of an Albany convenience store captured on surveillance; victim described two masked men, one wearing gray gloves and acting as the gunman.
Police found a silver sedan ~30 minutes later with Dowell, Montavious Hunt, and Eugene Watkins; officers smelled marijuana, detained occupants, and searched the vehicle.
Items consistent with the robbery were in the car or on Dowell: black firearm, black mask, black clothing, khaki pants, white socks, a cash band, large amount of cash on Hunt and Watkins, and one gray glove found on Dowell (the other glove was blue).
Hunt pleaded guilty and testified for the State, identifying Watkins as the driver and Dowell as the gunman.
The trial court granted Dowell a new trial, finding the evidence insufficient to sustain the convictions and, alternatively, granting relief as the thirteenth juror on general grounds.
The Court of Appeals reversed the trial court’s insufficiency ruling (holding there was corroboration) but affirmed the grant of a new trial under the general‑grounds (thirteenth juror) standard.

Issue	State's Argument	Dowell's Argument	Held
Whether evidence was legally sufficient/corroborated accomplice testimony	Hunt’s testimony corroborated by physical proximity and items (mask, gun, clothing, gray glove) found in/near vehicle	No independent corroboration tied Dowell to the robbery; accomplice testimony alone insufficient	Court of Appeals: Evidence was sufficient; trial court erred in finding insufficient evidence (reversed that part)
Whether trial court abused discretion in granting new trial on general grounds	The verdict was supported by the evidence; grant was an abuse of discretion	Trial judge, as thirteenth juror, properly weighed witness credibility and found the evidence preponderated against the verdict	Court of Appeals: No abuse of discretion; trial court properly exercised thirteenth‑juror role and new trial affirmed

Johnson v. State, 288 Ga. 803 (corroboration may be slight and need not be direct)
Raines v. State, 304 Ga. 582 (corroboration must be independent and may support inference of guilt)
Matthews v. State, 284 Ga. 819 (sufficiency of corroboration is for the trier of fact)
Savage v. State, 298 Ga. App. 350 (corroboration where defendant was with accomplices and contraband related to the crime was found)
Green v. State, 298 Ga. App. 17 (physical proximity to contraband in accomplice’s vehicle can corroborate accomplice testimony)
State v. Jackson, 294 Ga. 9 (reversing a trial court’s grant of new trial on ground of legal insufficiency)
White v. State, 293 Ga. 523 (explaining the general‑grounds/thirteenth‑juror standard)
State v. Beard, 307 Ga. 160 (discussing limits and application of discretion to grant new trial on general grounds)