section 24-14-8 accomplice corroboration requirement (Georgia) · Go Syfert
← Georgia issues

section 24-14-8 accomplice corroboration requirement in Georgia

11 Georgia opinions name it 2 courts 2017–2025 5 in the last five years

The cases below were cited by Georgia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Stanbury v. Stategreen
ga · 2016 · cited in 3 Georgia opinions naming this issue, 2019–2019
2 sentences

2019Stanbury v. State , 299 Ga. 125 , 129-130 (2), 786 S.E.2d 672 (2016) ; Hamm v. State , 294 Ga. 791 , 794-97 (2), 756 S.E.2d 507 (2014). 12 However, the record makes clear that Vasquez intentionally relinquished his right to have the jury instructed as to the accomplice-corroboration requirement under OCGA § 24-14-8.

2019Stanbury v. State , 299 Ga. 125 , 129-130 (2), 786 S.E.2d 672 (2016) ; Hamm v. State , 294 Ga. 791 , 794-97 (2), 756 S.E.2d 507 (2014). 12 However, the record makes clear that Vasquez intentionally relinquished his right to have the jury instructed as to the accomplice-corroboration requirement under OCGA § 24-14-8.

23
Hamm v. Stategreen
ga · 2014 · cited in 3 Georgia opinions naming this issue, 2017–2019
2 sentences

2019Stanbury v. State , 299 Ga. 125 , 129-130 (2), 786 S.E.2d 672 (2016) ; Hamm v. State , 294 Ga. 791 , 794-97 (2), 756 S.E.2d 507 (2014). 12 However, the record makes clear that Vasquez intentionally relinquished his right to have the jury instructed as to the accomplice-corroboration requirement under OCGA § 24-14-8.

2019Stanbury v. State , 299 Ga. 125 , 129-130 (2), 786 S.E.2d 672 (2016) ; Hamm v. State , 294 Ga. 791 , 794-97 (2), 756 S.E.2d 507 (2014). 12 However, the record makes clear that Vasquez intentionally relinquished his right to have the jury instructed as to the accomplice-corroboration requirement under OCGA § 24-14-8.

23
Johnson v. Stategreen
ga · 2021 · cited in 2 Georgia opinions naming this issue, 2022–2022
2 sentences

2022Moreover, if the evidence “would have authorized a properly instructed jury to find that a witness was not an accomplice, that finding would eliminate the need for corroboration under OCGA § 24-14-8, and the witness’ testimony alone could be sufficient to convict.” Johnson v. State, 311 Ga. 221, 223 (857 SE2d 463) (2021) (emphasis in original).

2022Moreover, if the evidence “would have authorized a properly instructed jury to find that a witness was not an accomplice, that finding would eliminate the need for corroboration under OCGA § 24-14-8, and the witness’ testimony alone could be sufficient to convict.” Johnson v. State, 311 Ga. 221, 223 (857 SE2d 463) (2021) (emphasis in original).

22
State v. GRIER (And Vice Versa)green
ga · 2020 · cited in 2 Georgia opinions naming this issue, 2020–2021
2 sentences

2021See State v. Grier, 309 Ga. 452, 456 (2) ( 847 SE2d 313 ) (2020); see also Fisher v. State, 309 Ga. 814, 819 (2) (a) ( 848 SE2d 434 ) (2020); Kelly v. State, 270 Ga. 523, 525 (2) ( 511 SE2d 169 ) (1999).

2021See State v. Grier, 309 Ga. 452, 456 (2) ( 847 SE2d 313 ) (2020); see also Fisher v. State, 309 Ga. 814, 819 (2) (a) ( 848 SE2d 434 ) (2020); Kelly v. State, 270 Ga. 523, 525 (2) ( 511 SE2d 169 ) (1999).

22
Lynn v. Stategreen
ga · 2020 · cited in 1 Georgia opinions naming this issue, 2025–2025
2 sentences

2025Each of Appellant’s assertions fail, as explained below. 24 “To prevail on any of his claims, [Appellant] must show both that his counsel’s performance was constitutionally deficient and that he was prejudiced by this deficient performance.” Lynn v. State, 310 Ga. 608, 612 (4) ( 852 SE2d 843 ) (2020) (citing Strickland v. Washington, 466 U. S. 668, 687 (III) ( 104 SCt 2052 , 80 LE2d 674) (1984)).

2025Each of Appellant’s assertions fail, as explained below. 24 “To prevail on any of his claims, [Appellant] must show both that his counsel’s performance was constitutionally deficient and that he was prejudiced by this deficient performance.” Lynn v. State, 310 Ga. 608, 612 (4) ( 852 SE2d 843 ) (2020) (citing Strickland v. Washington, 466 U. S. 668, 687 (III) ( 104 SCt 2052 , 80 LE2d 674) (1984)).

11
Jefferson v. Stategreen
ga · 2021 · cited in 1 Georgia opinions naming this issue, 2025–2025
2 sentences

2025See also Jefferson v. State, 310 Ga. 725, 726-727 (854 SE2d 528) (2021) (“Once a reviewing court reverses a conviction solely for insufficiency of the evidence to sustain the jury’s verdict of guilty, double jeopardy bars retrial.” (citation and punctuation omitted)). 3.

2025See also Jefferson v. State, 310 Ga. 725, 726-727 (854 SE2d 528) (2021) (“Once a reviewing court reverses a conviction solely for insufficiency of the evidence to sustain the jury’s verdict of guilty, double jeopardy bars retrial.” (citation and punctuation omitted)). 3.

11
Strickland v. Washingtongreen
scotus · 1984 · cited in 1 Georgia opinions naming this issue, 2025–2025
2 sentences

2025Each of Appellant’s assertions fail, as explained below. 24 “To prevail on any of his claims, [Appellant] must show both that his counsel’s performance was constitutionally deficient and that he was prejudiced by this deficient performance.” Lynn v. State, 310 Ga. 608, 612 (4) ( 852 SE2d 843 ) (2020) (citing Strickland v. Washington, 466 U. S. 668, 687 (III) ( 104 SCt 2052 , 80 LE2d 674) (1984)).

2025Each of Appellant’s assertions fail, as explained below. 24 “To prevail on any of his claims, [Appellant] must show both that his counsel’s performance was constitutionally deficient and that he was prejudiced by this deficient performance.” Lynn v. State, 310 Ga. 608, 612 (4) ( 852 SE2d 843 ) (2020) (citing Strickland v. Washington, 466 U. S. 668, 687 (III) ( 104 SCt 2052 , 80 LE2d 674) (1984)).

11
Taylor v. Stategreen
ga · 2015 · cited in 1 Georgia opinions naming this issue, 2025–2025
2 sentences

2025See Taylor, 297 Ga. at 135 (2) (reversing a conviction for 18 inadequate accomplice corroboration under OCGA § 24-14-8’s statutory precursor); Cowart v. State, 294 Ga. 333, 343 (6) ( 751 SE2d 399 ) (2013) (explaining that, “if the evidence of [the defendant’s] guilt was legally insufficient” under Georgia’s accomplice- corroboration statute, “he could not be retried”).

2025See Taylor, 297 Ga. at 135 (2) (reversing a conviction for inadequate accomplice corroboration under OCGA § 24-14-8’s statutory precursor); Cowart v. State, 294 Ga. 333, 343 (6) (751 SE2d 399) (2013) (explaining that, “if the evidence of [the defendant’s] guilt was legally insufficient” under Georgia’s accomplice- corroboration statute, “he could not be retried”).

11
Cowart v. Stategreen
ga · 2013 · cited in 1 Georgia opinions naming this issue, 2025–2025
2 sentences

2025See Taylor, 297 Ga. at 135 (2) (reversing a conviction for inadequate accomplice corroboration under OCGA § 24-14-8’s statutory precursor); Cowart v. State, 294 Ga. 333, 343 (6) (751 SE2d 399) (2013) (explaining that, “if the evidence of [the defendant’s] guilt was legally insufficient” under Georgia’s accomplice- corroboration statute, “he could not be retried”).

2025See Taylor, 297 Ga. at 135 (2) (reversing a conviction for inadequate accomplice corroboration under OCGA § 24-14-8’s statutory precursor); Cowart v. State, 294 Ga. 333, 343 (6) (751 SE2d 399) (2013) (explaining that, “if the evidence of [the defendant’s] guilt was legally insufficient” under Georgia’s accomplice- corroboration statute, “he could not be retried”).

11
Fisher v. Stategreen
ga · 2020 · cited in 1 Georgia opinions naming this issue, 2021–2021
2 sentences

2021See State v. Grier, 309 Ga. 452, 456 (2) ( 847 SE2d 313 ) (2020); see also Fisher v. State, 309 Ga. 814, 819 (2) (a) ( 848 SE2d 434 ) (2020); Kelly v. State, 270 Ga. 523, 525 (2) ( 511 SE2d 169 ) (1999).

2021See State v. Grier, 309 Ga. 452, 456 (2) ( 847 SE2d 313 ) (2020); see also Fisher v. State, 309 Ga. 814, 819 (2) (a) ( 848 SE2d 434 ) (2020); Kelly v. State, 270 Ga. 523, 525 (2) ( 511 SE2d 169 ) (1999).

11
Kelly v. Stategreen
ga · 1999 · cited in 1 Georgia opinions naming this issue, 2021–2021
2 sentences

2021See State v. Grier, 309 Ga. 452, 456 (2) ( 847 SE2d 313 ) (2020); see also Fisher v. State, 309 Ga. 814, 819 (2) (a) ( 848 SE2d 434 ) (2020); Kelly v. State, 270 Ga. 523, 525 (2) ( 511 SE2d 169 ) (1999).

2021See State v. Grier, 309 Ga. 452, 456 (2) ( 847 SE2d 313 ) (2020); see also Fisher v. State, 309 Ga. 814, 819 (2) (a) ( 848 SE2d 434 ) (2020); Kelly v. State, 270 Ga. 523, 525 (2) ( 511 SE2d 169 ) (1999).

11
State v. Caffeegreen
ga · 2012 · cited in 1 Georgia opinions naming this issue, 2021–2021
2 sentences

2021(Citation and punctuation omitted; emphasis supplied.) Wetzel v. State, 298 Ga. 20, 28 (3) ( 779 SE2d 263 ) (2015) (citing State v. Caffee, 291 Ga. 31, 34 (3) ( 728 SE2d 171 ) (2012)).2 And if the evidence at the 2 While Georgia law prohibits conviction on the uncorroborated 5 original trial would have authorized a properly instructed jury to find that a witness was not an accomplice, that finding would eliminate the need for corroboration under OCGA § 24-14-8, and the witness’ testimony alone could be sufficient to convict.

2021(Citation and punctuation omitted; emphasis supplied.) Wetzel v. State, 298 Ga. 20, 28 (3) ( 779 SE2d 263 ) (2015) (citing State v. Caffee, 291 Ga. 31, 34 (3) ( 728 SE2d 171 ) (2012)).2 And if the evidence at the 2 While Georgia law prohibits conviction on the uncorroborated 5 original trial would have authorized a properly instructed jury to find that a witness was not an accomplice, that finding would eliminate the need for corroboration under OCGA § 24-14-8, and the witness’ testimony alone could be sufficient to convict.

11
Wetzel v. Stategreen
ga · 2015 · cited in 1 Georgia opinions naming this issue, 2021–2021
2 sentences

2021(Citation and punctuation omitted; emphasis supplied.) Wetzel v. State, 298 Ga. 20, 28 (3) ( 779 SE2d 263 ) (2015) (citing State v. Caffee, 291 Ga. 31, 34 (3) ( 728 SE2d 171 ) (2012)).2 And if the evidence at the 2 While Georgia law prohibits conviction on the uncorroborated 5 original trial would have authorized a properly instructed jury to find that a witness was not an accomplice, that finding would eliminate the need for corroboration under OCGA § 24-14-8, and the witness’ testimony alone could be sufficient to convict.

2021(Citation and punctuation omitted; emphasis supplied.) Wetzel v. State, 298 Ga. 20, 28 (3) ( 779 SE2d 263 ) (2015) (citing State v. Caffee, 291 Ga. 31, 34 (3) ( 728 SE2d 171 ) (2012)).2 And if the evidence at the 2 While Georgia law prohibits conviction on the uncorroborated 5 original trial would have authorized a properly instructed jury to find that a witness was not an accomplice, that finding would eliminate the need for corroboration under OCGA § 24-14-8, and the witness’ testimony alone could be sufficient to convict.

11
Vasquez v. Stategreen
ga · 2019 · cited in 1 Georgia opinions naming this issue, 2020–2020
1 sentence

2020See Vasquez, supra at 229 (2) (c).

11
Jackson v. Stategreen
ga · 2013 · cited in 1 Georgia opinions naming this issue, 2019–2019
2 sentences

2019Under the plain error analysis articulated in Kelly, an objection is 12 The Attorney General argues that such an instruction was not required under this Court’s decision in Jackson v. State, 294 Ga. 34, 36 (2) ( 751 SE2d 63 ) (2013), which noted in dicta that “[w]here an accomplice witness’s testimony is independently corroborated, a jury instruction on corroboration is not required, whether or not the charge was requested by counsel.” However, this proposition in Jackson (and a line of cases preceding it) was explicitly overruled in Hamm.

2019Under the plain error analysis articulated in Kelly, an objection is 12 The Attorney General argues that such an instruction was not required under this Court’s decision in Jackson v. State, 294 Ga. 34, 36 (2) ( 751 SE2d 63 ) (2013), which noted in dicta that “[w]here an accomplice witness’s testimony is independently corroborated, a jury instruction on corroboration is not required, whether or not the charge was requested by counsel.” However, this proposition in Jackson (and a line of cases preceding it) was explicitly overruled in Hamm.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Georgia. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
United States v. Olano red
scotus · 1993
2 sentences

2019Under the plain-error analysis articulated in Kelly , an objection is intentionally relinquished or abandoned if it is "affirmatively waived." Applying the standard articulated in United States v. Olano , 507 U. S. 725 , 113 S.Ct. 1770 , 123 L.E.2d 508 (1993), we have contrasted such a waiver-the intentional relinquishment of a known right-with "forfeiture," which is the mere "failure to make the timely assertion of the right." Cheddersingh v. State , 290 Ga. 680 , 684 (2), 724 S.E.2d 366 (2012).

2019Under the plain-error analysis articulated in Kelly , an objection is intentionally relinquished or abandoned if it is "affirmatively waived." Applying the standard articulated in United States v. Olano , 507 U. S. 725 , 113 S.Ct. 1770 , 123 L.E.2d 508 (1993), we have contrasted such a waiver-the intentional relinquishment of a known right-with "forfeiture," which is the mere "failure to make the timely assertion of the right." Cheddersingh v. State , 290 Ga. 680 , 684 (2), 724 S.E.2d 366 (2012).

12019–2019
Cheddersingh v. State green
ga · 2012
2 sentences

2019Under the plain-error analysis articulated in Kelly , an objection is intentionally relinquished or abandoned if it is "affirmatively waived." Applying the standard articulated in United States v. Olano , 507 U. S. 725 , 113 S.Ct. 1770 , 123 L.E.2d 508 (1993), we have contrasted such a waiver-the intentional relinquishment of a known right-with "forfeiture," which is the mere "failure to make the timely assertion of the right." Cheddersingh v. State , 290 Ga. 680 , 684 (2), 724 S.E.2d 366 (2012).

2019Under the plain-error analysis articulated in Kelly , an objection is intentionally relinquished or abandoned if it is "affirmatively waived." Applying the standard articulated in United States v. Olano , 507 U. S. 725 , 113 S.Ct. 1770 , 123 L.E.2d 508 (1993), we have contrasted such a waiver-the intentional relinquishment of a known right-with "forfeiture," which is the mere "failure to make the timely assertion of the right." Cheddersingh v. State , 290 Ga. 680 , 684 (2), 724 S.E.2d 366 (2012).

12019–2019

Statutes the citing opinions construe

GA § 24-14-8 (11) GA § 17-8-58 (5) GA § 24-4-404 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

← Caselaw search · G Cite Topics · Brief Check