Taylor v. State, 297 Ga. 132

On Dec. 21, 2008, three people were killed and others shot at an apartment in Kingsland, GA; defendants Taylor and Bessent were tried jointly with co-defendant Stuckey and accomplice witness Brown.
Brown testified he drove Taylor, Bessent, and Stuckey from Florida to Georgia, that Stuckey carried an AK-47, and that all three entered the victim’s apartment where shots were fired; phone records showed calls between Stuckey’s phone and victim Michael Key shortly before the shootings.
Meagan Molix (roommate) testified that two men (one taller, one shorter) entered the bedroom asking about drugs; at trial she identified Taylor as the taller man but was equivocal.
Physical evidence included two types of shell casings inside the apartment and Wolf-brand AK-47 casings outside; a Wolf-brand bullet was later found at Stuckey’s home.
Additional evidence: rap lyrics written by Taylor in jail referencing “choppas” (AK-47) and becoming a co-defendant with Stuckey; eyewitness Jones saw Bessent with Taylor and Stuckey after the murders.
Verdicts: both defendants convicted of felony murder, aggravated assault, and related conspiracies; Taylor’s convictions affirmed, Bessent’s convictions reversed for insufficient corroboration of accomplice testimony.

Issue	Taylor's Argument	Bessent's Argument	Held
Whether Brown’s accomplice testimony was sufficiently corroborated to support conviction	Brown’s testimony was corroborated by Molix’s ID and Taylor’s jailhouse lyrics linking him to an AK-47 and Stuckey	Brown’s testimony lacked independent corroboration tying Bessent to the crimes; post-crime presence in Florida insufficient	Taylor: corroboration sufficient; conviction affirmed. Bessent: corroboration insufficient; convictions reversed.
Admissibility of Taylor’s jailhouse rap lyrics	Lyrics were relevant and probative because they referenced an AK-47 and co-defendant status	Lyrics were irrelevant and unduly prejudicial	Lyrics were relevant; trial court did not abuse discretion admitting them.
Whether phone records corroborated accomplice testimony	(State) Phone records showing calls between Stuckey’s phone and victim corroborated Brown’s account for involvement of defendants	(Defense) Records do not show Bessent made calls or otherwise tie him specifically	Phone records did not corroborate Brown’s assertion that Bessent made the calls; they did not salvage Bessent’s insufficiently corroborated testimony.
Whether sufficiency review standard satisfied (Jackson v. Virginia)	Evidence viewed in light most favorable to verdict supports convictions if corroboration exists	Evidence insufficient for Bessent absent independent proof of participation	Standard applied; evidence sufficient for Taylor but insufficient for Bessent.

Threatt v. State, 293 Ga. 549 (discussion of accomplice corroboration requirement)
Crawford v. State, 294 Ga. 898 (corroboration must independently connect defendant to crime)
Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
Castillo v. State, 281 Ga. 579 (admission of evidence discretion)
Johnson v. State, 294 Ga. 86 (weight of equivocal identification for jury)
West v. State, 232 Ga. 861 (corroboration must tend to show defendant’s participation)
O'Neal v. State, 254 Ga. 1 (trial court discretion on relevancy ruling)