Teasley v. State, 288 Ga. 468

Appellant Christopher Teasley and his brothers were convicted of malice murder, felony murder, and aggravated assault in the 2005 shooting spree that also involved a 15-year-old cousin and James Riden.
Tyrone Teasley retrieved a gun, Emory Teasley shot at Jones, and Appellant drove the vehicle and helped eject the firearm after the crime.
The jury also found Appellant guilty of possession of a firearm during a crime and tampering with evidence; the felony murder conviction was vacated by operation of law, and the aggravated assault of Riden merged into malice murder.
Appellant drove his brothers to the pool hall/killing scene, remained present, and aided in the confrontation and flight from the scene.
Tyrone threw the gun out the car window as Appellant drove away, which the State argued supported Appellant’s status as a party to the crimes.
The trial court sentenced Appellant to life for murder, five years for the weapons charge, 20 years for aggravated assault, and three years for tampering with evidence; a new-trial motion was denied and appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was sufficient evidence Appellant was a party to the crimes	Teasley was merely present at the scene.	Teasley was a party to the crimes through presence, companionship, and conduct.	Evidence supported party liability for all crimes.
Whether the tampering with evidence conviction and sentence were proper given Tyrone’s direct commission	Appellant aided in concealing the firearm and coordinated the flight.	Tampering was performed as part of a conspiracy/accomplice liability for the crimes.	Tampering sentence vacated; remanded for resentencing on that conviction.

Walsh v. State, 269 Ga. 427 (1998) (presence can support party liability when coupled with conduct.)
Yancey v. State, 281 Ga. 664 (2004) (driver role and aiding conduct supports liability.)
Lucky v. State, 286 Ga. 478 (2010) (slight circumstances can support inference of collusion when relatives are involved.)
Adamson v. State, 238 Ga.App. 105 (1999) (proof of joint participation may be inferred from presence and conduct.)
Beadles v. State, 259 Ga. 519 (1989) (accomplice liability for crimes can impute acts to another.)
Cooper v. State, 287 Ga. 861 (2010) (evidence of acts by co-conspirator supports liability for related offenses.)
White v. State, 287 Ga. 713 (2010) (apparent limitation on certain sentencing when other defendant committed the act.)
Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency standard for criminal convictions.)