Worthen v. State, 306 Ga. 600

In April 2012, Jacquez Worthen and three others (including Jhakeem Armstrong) were involved in an altercation that began at a house party and culminated in the fatal shooting of Robert Parrish, Jr., at a park on April 8.
At the park Worthen argued with Parrish’s son; Parrish intervened. During a crowded confrontation, Armstrong pulled a gun and shot Parrish multiple times; Worthen and Armstrong then fled together.
Witnesses and photographs tied Worthen, Armstrong, Armstrong’s brother, and another person to the same Crips sub-group (blue bandannas, hand signs, tattoos). A gang expert testified about gang culture, respect, and violent responses to perceived disrespect.
Worthen was tried jointly with Jhakeem Armstrong, convicted of felony murder (predicated on aggravated assault) and aggravated assault (merged into murder sentence), and sentenced to life. He moved for a new trial and appealed.
Worthen challenged (1) sufficiency of the evidence to convict him as a party to Armstrong’s shooting and (2) the trial court’s admission of gang-membership evidence under OCGA § 24-4-404(b). The Georgia Supreme Court affirmed.

Issue	Plaintiff's Argument (Worthen)	Defendant's Argument (State)	Held
Sufficiency: Was evidence adequate to convict Worthen as a party to aggravated assault (and thus felony murder)?	Worthen: Only Armstrong fired the shots; Worthen did not aid/abet or advise/encourage the shooting.	State: Worthen’s presence, gang ties, statements ("some boys coming"), asking Armstrong if he had a gun, Armstrong’s verbal cues, joint flight, and gang culture evidence support inference Worthen encouraged/abetted the shooting.	Affirmed — a rational jury could infer Worthen advised/encouraged/abetted the shooting; evidence sufficient under party liability and Jackson v. Virginia review.
Admissibility: Was gang-membership/other-acts evidence admissible under Rule 404(b)?	Worthen: The gang evidence was offered to show propensity/character and was unfairly prejudicial.	State: Evidence was relevant to motive (gang retaliation for perceived disrespect); probative value not substantially outweighed by unfair prejudice; sufficient proof by preponderance supported admission.	Affirmed — trial court did not abuse discretion: evidence admissible to show motive and context; probative value outweighed prejudice.

Herrington v. State, 300 Ga. 149 (party liability can be inferred from presence, companionship, and conduct)
Davis v. State, 305 Ga. 869 (credibility and conflict-resolution are jury functions)
Butts v. State, 297 Ga. 766 (common criminal intent may be inferred from conduct before/during/after the crime)
Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence)
Hood v. State, 299 Ga. 95 (standard and deference for admitting other-acts evidence under Rule 404(b))
Anglin v. State, 302 Ga. 333 (gang membership evidence may be relevant to motive in gang-related homicides)