Williams v. State, 289 Ga. 672

Kelvin Williams was convicted of malice murders of Brian Stringer and Myron Long, along with other crimes, and affirmed on appeal denying his new-trial motion.
The State proved that Stringer was sent with $22,500 to purchase a kilogram of cocaine, but defendants planned to substitute a fake brick to obtain the money.
Appellant aided the plan by seeking information on making a fake brick from witness Robert Jones, who provided general substances but not packaging instructions.
Co-defendants used witness John Jackson’s home to stage the sale; victims were shot when they approached for directions, with Robinson seen fleeing and identified by Jackson.
Expert testimony showed Stringer died from a gunshot to the back of the head and Long from a gunshot to the front left shoulder; no drugs or weapons were recovered at the scene.
Jones later provided information to police, including appellant’s admission that they “messed up” by setting up the fake brick sale and shooting the victims; appellant accused Robinson of being the shooter during later interviews.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence with a sole accomplice-witness	Jones was the sole witness and an accomplice; no corroboration for murder and other crimes	Jones cannot be accomplice; insufficient to sustain convictions	Evidence was sufficient; rational jury could convict beyond reasonable doubt
Effect of hearsay-related admission of Jones's statements	Trial counsel should have objected to hearsay within Jones's statements	No meritorious objection; prior consistent statements properly admitted	Counsel's performance not deficient; admission proper under governing rules
Admissibility of Jones's statements about co-defendant Robinson during concealment phase	Robinson's statements should be admissible as co-conspirator statements	Jones's testimony violated confrontation clause and is improper	Admission proper; Confrontation Clause not violated; statements not testimonial

Jackson v. State, 278 Ga. 235, 236(1), 599 S.E.2d 129 (2004) (accomplice liability requires sharing a common criminal intent)
Jackson v. Virginia, 443 U.S. 307, 99 S. Ct. 2781, 61 L. Ed. 2d 560 (1979) (sufficiency of evidence review for federal constitutional adequacy)
Woodard v. State, 269 Ga. 317, 496 S.E.2d 896 (1998) (prior consistent statements admissible when witness credibility is attacked)
Wesley v. State, 286 Ga. 355, 689 S.E.2d 280 (2010) (meritless objections cannot support ineffective assistance)
Allen v. State, 288 Ga. 263, 702 S.E.2d 869 (2010) (co-conspirator statements admissible during conspiracy proceedings)