Young v. State, 291 Ga. 627

Appellant Christopher Young and co-defendant Satterfield were tried for felony murder with burglary as predicate, burglary, armed robbery, possession of a firearm during the crime, and misdemeanor possession of marijuana.
The 78-year-old victim was killed by a single gunshot wound during a break-in at his Muscogee County home, with entry gained via a broken bedroom window and the gun cabinet contents disturbed.
Dominic Tinch testified for the State, saying he drove the trio and that Young stated he shot the victim; Tinch met Young and Satterfield near the residence.
A neighbor testified that Satterfield told him the day after the shooting that Young had participated and that Young shot the victim after they entered via a window.
The jury found Young guilty of all charged offenses; he received life for felony murder with concurrent burglary and armed robbery sentences, a misdemeanor marijuana sentence, and a consecutive five-year firearm sentence.
The trial court later vacated the burglary conviction as the predicate felony for felony murder, vacating the separate burglary judgment and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of corroboration for accomplice testimony	Tinch's testimony alone is insufficient; corroboration required.	Neighbor's out-of-court statement provides sufficient corroboration under OCGA § 24-4-8.	Sufficient corroboration existed; neighbor testimony supported Tinch's accomplice testimony.
Constitutional confrontation with hearsay under conspiracy	Neighbor's testimony citing Satterfield is admissible as conspiracy-related hearsay.	Admission violates Confrontation Clause since co-defendant did not testify.	Admissible under co-conspirator hearsay exception; did not violate Confrontation Clause.
Burglary as predicate for felony murder and sentence	Burglary supports felony murder; cannot vacate related sentence.	Burglary cannot serve as predicate for felony murder without double punishment.	Burglary sentence vacated as predicate felony for felony murder; not allowed to sentence both.
Reopening the State's case after resting	Reopening was improper if it surprised defendants.	Trial court acted within discretion to seek truth and avoid injustice.	No abuse of discretion; reopening was permissible under the circumstances.
Right to a directed verdict and timing of evidence	State's late disclosure after resting undermined motions for acquittal.	State acted in good faith with reasonable efforts to locate witnesses.	No abuse of discretion; evidence reopened appropriately.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review requires reasonable doubt standard)
Sapp v. State, 290 Ga. 247 (Ga. 2011) (double-punishment concerns for predicate offenses)
OCGA § 24-4-8, citational reference (statutory) (requires corroboration in single-witness accomplice cases)
OCGA § 24-3-5, citation not provided here (statutory) (co-conspirator statements admissible against all)
Allen v. State, 288 Ga. 263 (Ga. 2010) (non-testifying co-conspirator statements admissible per hearsay exception)
Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (confrontation clause does not apply to testimonial hearsay)
Danenberg v. State, 291 Ga. 439 (Ga. 2012) (trial court discretion in reopening evidence)
Taylor v. State, 282 Ga. 502 (Ga. 2007) (recognizes broad discretion to discover truth in trial procedure)
Peeples v. State, 234 Ga. App. 454 (Ga. App. 1998) (reopening evidence post-directed verdict not per se abusive)