Watt v. State, 317 Ga. App. 551

Watt was convicted of trafficking marijuana after a jury trial; corroboration of an accomplice’s testimony was at issue.
The State’s case relied on Forsyth’s testimony that Watt was involved in obtaining the 150 pounds of marijuana from the warehouse.
Police linked Watt to the crime through timing and vehicle evidence, including Watt’s Camry with tools that could open a crate.
A 2003 Tucson arrest for marijuana trafficking was admitted as similar-transaction evidence to show Watt’s bent of mind.
A BOLO for a silver Camry led to a stop of Watt’s vehicle where officers found tools and Watt was detained; Forsyth testified to planning the import.
Forsyth’s and Watt’s relatives testified to Watt’s involvement and to the rental/loan of the car used for the delivery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of corroboration for accomplice's testimony	Watt corroboration supported Forsyth	Forsyth alone insufficient to convict	Sufficient corroboration exists
Reasonableness of vehicle stop	BOLO created reasonable suspicion	Stop unsupported by suspicion	Stop valid under reasonable-suspicion standard
Admissibility of similar transaction evidence	12-hour prior marijuana transaction shows bent of mind	Not sufficiently similar or probative	Admissible; sufficient similarity and probative value

Clyde v. State, 298 Ga. App. 283 (680 SE2d 146) (2009) (Ga. App. 2009) (cites admissibility of similar transaction or evidentiary precedent in Georgia)
James v. State, 316 Ga. App. 406, 408 (1) (730 SE2d 20) (2012) (Ga. App. 2012) (treatment of accomplice testimony and corroboration rules)
Gilmore v. State, 315 Ga. App. 85, 87 (1) (726 SE2d 584) (2012) (Ga. App. 2012) (discusses corroboration and admissibility standards)
Alatise v. State, 291 Ga. 428, 432 (5) (728 SE2d 592) (2012) (Ga. 2012) (admissibility and reasoning in corroboration contexts)
Copeny v. State, 316 Ga. App. 347, 350 (1) (729 SE2d 487) (2012) (Ga. App. 2012) (emphasizes reliance on corroboration standards)