Williams v. State, 304 Ga. 658

On January 22, 2014, Tyler Johnson was shot through his front door and later died; police linked a white Impala and a group of four men and one woman to the scene.
Edwin Williams and co-indictees (Jones, Rushton, Hollis, Warren) had discussed "hitting a lick" (robbery) the night before with guns present, and they reconnoitered the victim's neighborhood.
The group returned the next day; some wore disguising clothing and carried firearms; Warren knocked at the victim's door while the others approached the porch; Jones fired through the door, fatally wounding the victim.
Witnesses placed Williams on the porch at the time of the shooting; Williams fled with the others and was later arrested in the getaway car; a derringer recovered from Jones' house matched the fatal bullet's caliber but could not be forensically tied due to firearm damage.
A jury acquitted Williams of malice murder but convicted him of felony murder (predicate: attempt to commit armed robbery) and criminal attempt to commit armed robbery; he was sentenced to life with parole on both counts.
Williams appealed, arguing the evidence was insufficient to convict him as a party to the crimes; the State argued the circumstantial evidence supported party liability. The Supreme Court of Georgia reviewed sufficiency and sentencing-merger issues.

Issue	Williams' Argument	State's Argument	Held
Sufficiency of evidence to convict Williams as a party to felony murder and attempted armed robbery	Evidence only shows presence and one conversation about a robbery; insufficient to prove he shared criminal intent	Williams' precrime discussions, conduct during (on porch with group, disguised clothing, firearms present), and flight support an inference he intentionally aided/abetted	Conviction affirmed — jury properly could infer Williams shared common criminal intent and was a party to the crimes
Sentencing: whether separate sentence for attempt to commit armed robbery was authorized	Trial court imposed life with parole on both counts; Williams implicitly argued duplication/unauthorized extra sentence	State conceded the attempt count merged into felony murder and only one sentence was authorized	Judgment vacated in part — sentence for criminal attempt to commit armed robbery vacated; life with parole for felony murder affirmed

Harper v. State, 298 Ga. 158 (review standard for sufficiency of evidence)
Conway v. State, 281 Ga. 685 (party liability may be inferred from presence, companionship, conduct before/during/after)
Sims v. State, 281 Ga. 541 (conduct before/during/after can show intentional encouragement and shared intent)
Coggins v. State, 275 Ga. 479 (participants in a robbery are responsible for acts that are probable consequences)
Moore v. State, 275 Ga. 51 (merger of underlying felony with felony murder prevents separate sentence)