corroboration requirement in Georgia

2022See Palencia, 359 Ga. App. at 311 (3) (a) (citing Glaze v. State, 317 Ga. App. 679, 681-682 (1) (732 SE2d 771) (2012) (given the absence of any corroboration requirement in the rape statute, a victim’s testimony that she was raped by someone matching the defendant’s description was sufficient to sustain the rape conviction), and Baker v. State, 245 Ga. 657, 665-666 (5) (266 SE2d 477) (1980) (noting the General Assembly’s 1978 removal of the corroboration requirement from the rape statute, OCGA § 16-6-1)).

2022See Palencia, 359 Ga. App. at 311 (3) (a) (citing Glaze v. State, 317 Ga. App. 679, 681-682 (1) (732 SE2d 771) (2012) (given the absence of any corroboration requirement in the rape statute, a victim’s testimony that she was raped by someone matching the defendant’s description was sufficient to sustain the rape conviction), and Baker v. State, 245 Ga. 657, 665-666 (5) (266 SE2d 477) (1980) (noting the General Assembly’s 1978 removal of the corroboration requirement from the rape statute, OCGA § 16-6-1)).

2022See Palencia, 359 Ga. App. at 311 (3) (a) (citing Glaze v. State, 317 Ga. App. 679, 681-682 (1) (732 SE2d 771) (2012) (given the absence of any corroboration requirement in the rape statute, a victim’s testimony that she was raped by someone matching the defendant’s description was sufficient to sustain the rape conviction), and Baker v. State, 245 Ga. 657, 665-666 (5) (266 SE2d 477) (1980) (noting the General Assembly’s 1978 removal of the corroboration requirement from the rape statute, OCGA § 16-6-1)).

2022See Palencia, 359 Ga. App. at 311 (3) (a) (citing Glaze v. State, 317 Ga. App. 679, 681-682 (1) (732 SE2d 771) (2012) (given the absence of any corroboration requirement in the rape statute, a victim’s testimony that she was raped by someone matching the defendant’s description was sufficient to sustain the rape conviction), and Baker v. State, 245 Ga. 657, 665-666 (5) (266 SE2d 477) (1980) (noting the General Assembly’s 1978 removal of the corroboration requirement from the rape statute, OCGA § 16-6-1)).

2018See Bradford v. State, 262 Ga. 512, 513 ( 421 SE2d 523 ) (1992). 8 the State has presented no other evidence to satisfy the corroboration requirement.

2018See Bradford v. State, 262 Ga. 512, 513 ( 421 SE2d 523 ) (1992). 8 the State has presented no other evidence to satisfy the corroboration requirement.

2017Brown v. State, 318 Ga. App. 334, 336 (1) ( 733 SE2d 863 ) (2012); Patterson v. State, 233 Ga. App. 776, 776 (1) ( 505 SE2d 518 ) (1998).

2017Brown v. State, 318 Ga. App. 334, 336 (1) ( 733 SE2d 863 ) (2012); Patterson v. State, 233 Ga. App. 776, 776 (1) ( 505 SE2d 518 ) (1998).

2017Brown v. State, 318 Ga. App. 334, 336 (1) ( 733 SE2d 863 ) (2012); Patterson v. State, 233 Ga. App. 776, 776 (1) ( 505 SE2d 518 ) (1998).

2017Brown v. State, 318 Ga. App. 334, 336 (1) ( 733 SE2d 863 ) (2012); Patterson v. State, 233 Ga. App. 776, 776 (1) ( 505 SE2d 518 ) (1998).

2013Furthermore, as the Supreme Court of Georgia has noted, the corroboration rule “is made more stringent by the requirement, not contained in the statute, that the [S]tate must provide corroboration of an accomplice’s testimony regarding the identification and participation of the defendant.” (Footnote omitted.) Parkerson v. State, 265 Ga. 438, 439 (2) ( 457 SE2d 667 ) (1995).

2013Furthermore, as the Supreme Court of Georgia has noted, the corroboration rule “is made more stringent by the requirement, not contained in the statute, that the [S]tate must provide corroboration of an accomplice’s testimony regarding the identification and participation of the defendant.” (Footnote omitted.) Parkerson v. State, 265 Ga. 438, 439 (2) ( 457 SE2d 667 ) (1995).

2008Kelly v. State, 270 Ga. 523, 525 (2) ( 511 SE2d 169 ) (1999).

2008Kelly v. State, 270 Ga. 523, 525 (2) ( 511 SE2d 169 ) (1999).

2018The purpose of the corroboration requirement is to "furnish[ ] the jury [with] a criterion for ascertaining the degree of credit which should be given to the testimony of the injured female." (Citation omitted.) Strickland v. State , 207 Ga. 284 , 287 (5), 61 S.E.2d 118 (1950).

2018The purpose of the corroboration requirement is to "furnish[ ] the jury [with] a criterion for ascertaining the degree of credit which should be given to the testimony of the injured female." (Citation omitted.) Strickland v. State , 207 Ga. 284 , 287 (5), 61 S.E.2d 118 (1950).

2010McLaren v. State, 4 Ga.App. 643, 646 , 62 S.E. 138 (1908).

2010McLaren v. State, 4 Ga. App. 643, 646 ( 62 SE 138 ) (1908).

2025Cf. Kim v. State, 309 Ga. 612, 617 (1) ( 847 SE2d 546 ) (2020) (“[T]he [factfinder] could reasonably infer that [appellant] lied to the police because he shared a common criminal intent with his associate and that the two acted in concert in committing the crimes.”).

2025Cf. Kim v. State, 309 Ga. 612, 617 (1) ( 847 SE2d 546 ) (2020) (“[T]he [factfinder] could reasonably infer that [appellant] lied to the police because he shared a common criminal intent with his associate and that the two acted in concert in committing the crimes.”).

2025See Veal v. State, 298 Ga. 691, 694-695 (2) ( 784 SE2d 403 ) 7 The State addressed the accomplice-corroboration issue and advanced this exact theory during closing argument, and the jury was subsequently charged on the corroboration requirement. 14 (2016) (sufficient corroborating evidence included evidence that co- defendants were members of the same gang), overruled on other grounds, Holmes v. State, 311 Ga. 698, 705 (3) ( 859 SE2d 475 ) (2021); Threatt, 293 Ga. at 551-552 (1) (accomplice’s testimony corroborated in part by appellant’s “demonstrably false” statements to police); Floyd v. Sta

2025See Veal v. State, 298 Ga. 691, 694-695 (2) ( 784 SE2d 403 ) 7 The State addressed the accomplice-corroboration issue and advanced this exact theory during closing argument, and the jury was subsequently charged on the corroboration requirement. 14 (2016) (sufficient corroborating evidence included evidence that co- defendants were members of the same gang), overruled on other grounds, Holmes v. State, 311 Ga. 698, 705 (3) ( 859 SE2d 475 ) (2021); Threatt, 293 Ga. at 551-552 (1) (accomplice’s testimony corroborated in part by appellant’s “demonstrably false” statements to police); Floyd v. Sta

2025See Veal v. State, 298 Ga. 691, 694-695 (2) ( 784 SE2d 403 ) 7 The State addressed the accomplice-corroboration issue and advanced this exact theory during closing argument, and the jury was subsequently charged on the corroboration requirement. 14 (2016) (sufficient corroborating evidence included evidence that co- defendants were members of the same gang), overruled on other grounds, Holmes v. State, 311 Ga. 698, 705 (3) ( 859 SE2d 475 ) (2021); Threatt, 293 Ga. at 551-552 (1) (accomplice’s testimony corroborated in part by appellant’s “demonstrably false” statements to police); Floyd v. Sta

2025See also Threatt, 293 Ga. at 551-552 (1) (rejecting argument that accomplice’s testimony was insufficiently corroborated because, in addition to other corroborating evidence, phone records showed that appellant and accomplice were in contact before the crimes and in the hours afterward). 6 As set forth in Division 2, the jury was properly instructed about the requirement for corroboration of an accomplice’s testimony and that the sufficiency of the corroborating evidence was a matter solely for the jury’s determination. 7 The State addressed the accomplice-corroboration issue and advanced this

2025See Veal v. State, 298 Ga. 691, 694-695 (2) ( 784 SE2d 403 ) 7 The State addressed the accomplice-corroboration issue and advanced this exact theory during closing argument, and the jury was subsequently charged on the corroboration requirement. 14 (2016) (sufficient corroborating evidence included evidence that co- defendants were members of the same gang), overruled on other grounds, Holmes v. State, 311 Ga. 698, 705 (3) ( 859 SE2d 475 ) (2021); Threatt, 293 Ga. at 551-552 (1) (accomplice’s testimony corroborated in part by appellant’s “demonstrably false” statements to police); Floyd v. Sta

2025See Veal v. State, 298 Ga. 691, 694-695 (2) ( 784 SE2d 403 ) 7 The State addressed the accomplice-corroboration issue and advanced this exact theory during closing argument, and the jury was subsequently charged on the corroboration requirement. 14 (2016) (sufficient corroborating evidence included evidence that co- defendants were members of the same gang), overruled on other grounds, Holmes v. State, 311 Ga. 698, 705 (3) ( 859 SE2d 475 ) (2021); Threatt, 293 Ga. at 551-552 (1) (accomplice’s testimony corroborated in part by appellant’s “demonstrably false” statements to police); Floyd v. Sta

2025See Veal v. State, 298 Ga. 691, 694-695 (2) ( 784 SE2d 403 ) 7 The State addressed the accomplice-corroboration issue and advanced this exact theory during closing argument, and the jury was subsequently charged on the corroboration requirement. 14 (2016) (sufficient corroborating evidence included evidence that co- defendants were members of the same gang), overruled on other grounds, Holmes v. State, 311 Ga. 698, 705 (3) ( 859 SE2d 475 ) (2021); Threatt, 293 Ga. at 551-552 (1) (accomplice’s testimony corroborated in part by appellant’s “demonstrably false” statements to police); Floyd v. Sta

2025See Veal v. State, 298 Ga. 691, 694-695 (2) ( 784 SE2d 403 ) 7 The State addressed the accomplice-corroboration issue and advanced this exact theory during closing argument, and the jury was subsequently charged on the corroboration requirement. 14 (2016) (sufficient corroborating evidence included evidence that co- defendants were members of the same gang), overruled on other grounds, Holmes v. State, 311 Ga. 698, 705 (3) ( 859 SE2d 475 ) (2021); Threatt, 293 Ga. at 551-552 (1) (accomplice’s testimony corroborated in part by appellant’s “demonstrably false” statements to police); Floyd v. Sta

2025See Miller v. State, 295 Ga. 769, 771 (1) ( 764 SE2d 135 ) (2014) (explaining that “accomplices can corroborate each other”). 21 Howard v. State, 318 Ga. 681 , 684 (1) ( 899 SE2d 669 ) (2024).

2025See Miller v. State, 295 Ga. 769, 771 (1) ( 764 SE2d 135 ) (2014) (explaining that “accomplices can corroborate each other”). 21 Howard v. State, 318 Ga. 681 , 684 (1) ( 899 SE2d 669 ) (2024).

2025See Miller v. State, 295 Ga. 769, 771 (1) ( 764 SE2d 135 ) (2014) (explaining that “accomplices can corroborate each other”). 21 Howard v. State, 318 Ga. 681 , 684 (1) ( 899 SE2d 669 ) (2024).

2025See Miller v. State, 295 Ga. 769, 771 (1) ( 764 SE2d 135 ) (2014) (explaining that “accomplices can corroborate each other”). 21 Howard v. State, 318 Ga. 681 , 684 (1) ( 899 SE2d 669 ) (2024).

2024Again, we disagree. 15 Farmer v. Dep’t of Corr., 346 Ga. App. 387, 394 (2) ( 816 SE2d 376 ) (2018) (punctuation omitted); see Woods v. Hall, 315 Ga. App. 93, 96 ( 726 SE2d 596 ) (2012) (“[A]n assertion of error followed by a case citation is not legal argument, which requires, at a minimum, a discussion of the appropriate law as applied to the relevant facts.” (punctuation omitted)). 16 See supra notes 13-14 & accompanying text. 11 We review de novo an allegedly erroneous jury instruction, which is “a legal question.”17 And in assessing the assertion that a jury instruction was erroneous, it m

2024Again, we disagree. 15 Farmer v. Dep’t of Corr., 346 Ga. App. 387, 394 (2) ( 816 SE2d 376 ) (2018) (punctuation omitted); see Woods v. Hall, 315 Ga. App. 93, 96 ( 726 SE2d 596 ) (2012) (“[A]n assertion of error followed by a case citation is not legal argument, which requires, at a minimum, a discussion of the appropriate law as applied to the relevant facts.” (punctuation omitted)). 16 See supra notes 13-14 & accompanying text. 11 We review de novo an allegedly erroneous jury instruction, which is “a legal question.”17 And in assessing the assertion that a jury instruction was erroneous, it m

2024Again, we disagree. 15 Farmer v. Dep’t of Corr., 346 Ga. App. 387, 394 (2) ( 816 SE2d 376 ) (2018) (punctuation omitted); see Woods v. Hall, 315 Ga. App. 93, 96 ( 726 SE2d 596 ) (2012) (“[A]n assertion of error followed by a case citation is not legal argument, which requires, at a minimum, a discussion of the appropriate law as applied to the relevant facts.” (punctuation omitted)). 16 See supra notes 13-14 & accompanying text. 11 We review de novo an allegedly erroneous jury instruction, which is “a legal question.”17 And in assessing the assertion that a jury instruction was erroneous, it m

2024Again, we disagree. 15 Farmer v. Dep’t of Corr., 346 Ga. App. 387, 394 (2) ( 816 SE2d 376 ) (2018) (punctuation omitted); see Woods v. Hall, 315 Ga. App. 93, 96 ( 726 SE2d 596 ) (2012) (“[A]n assertion of error followed by a case citation is not legal argument, which requires, at a minimum, a discussion of the appropriate law as applied to the relevant facts.” (punctuation omitted)). 16 See supra notes 13-14 & accompanying text. 11 We review de novo an allegedly erroneous jury instruction, which is “a legal question.”17 And in assessing the assertion that a jury instruction was erroneous, it m

2024Again, we disagree. 15 Farmer v. Dep’t of Corr., 346 Ga. App. 387, 394 (2) ( 816 SE2d 376 ) (2018) (punctuation omitted); see Woods v. Hall, 315 Ga. App. 93, 96 ( 726 SE2d 596 ) (2012) (“[A]n assertion of error followed by a case citation is not legal argument, which requires, at a minimum, a discussion of the appropriate law as applied to the relevant facts.” (punctuation omitted)). 16 See supra notes 13-14 & accompanying text. 11 We review de novo an allegedly erroneous jury instruction, which is “a legal question.”17 And in assessing the assertion that a jury instruction was erroneous, it m

2024Again, we disagree. 15 Farmer v. Dep’t of Corr., 346 Ga. App. 387, 394 (2) ( 816 SE2d 376 ) (2018) (punctuation omitted); see Woods v. Hall, 315 Ga. App. 93, 96 ( 726 SE2d 596 ) (2012) (“[A]n assertion of error followed by a case citation is not legal argument, which requires, at a minimum, a discussion of the appropriate law as applied to the relevant facts.” (punctuation omitted)). 16 See supra notes 13-14 & accompanying text. 11 We review de novo an allegedly erroneous jury instruction, which is “a legal question.”17 And in assessing the assertion that a jury instruction was erroneous, it m

2024Again, we disagree. 15 Farmer v. Dep’t of Corr., 346 Ga. App. 387, 394 (2) ( 816 SE2d 376 ) (2018) (punctuation omitted); see Woods v. Hall, 315 Ga. App. 93, 96 ( 726 SE2d 596 ) (2012) (“[A]n assertion of error followed by a case citation is not legal argument, which requires, at a minimum, a discussion of the appropriate law as applied to the relevant facts.” (punctuation omitted)). 16 See supra notes 13-14 & accompanying text. 11 We review de novo an allegedly erroneous jury instruction, which is “a legal question.”17 And in assessing the assertion that a jury instruction was erroneous, it m

2024Again, we disagree. 15 Farmer v. Dep’t of Corr., 346 Ga. App. 387, 394 (2) ( 816 SE2d 376 ) (2018) (punctuation omitted); see Woods v. Hall, 315 Ga. App. 93, 96 ( 726 SE2d 596 ) (2012) (“[A]n assertion of error followed by a case citation is not legal argument, which requires, at a minimum, a discussion of the appropriate law as applied to the relevant facts.” (punctuation omitted)). 16 See supra notes 13-14 & accompanying text. 11 We review de novo an allegedly erroneous jury instruction, which is “a legal question.”17 And in assessing the assertion that a jury instruction was erroneous, it m

2024Again, we disagree. 15 Farmer v. Dep’t of Corr., 346 Ga. App. 387, 394 (2) ( 816 SE2d 376 ) (2018) (punctuation omitted); see Woods v. Hall, 315 Ga. App. 93, 96 ( 726 SE2d 596 ) (2012) (“[A]n assertion of error followed by a case citation is not legal argument, which requires, at a minimum, a discussion of the appropriate law as applied to the relevant facts.” (punctuation omitted)). 16 See supra notes 13-14 & accompanying text. 11 We review de novo an allegedly erroneous jury instruction, which is “a legal question.”17 And in assessing the assertion that a jury instruction was erroneous, it m

2024Again, we disagree. 15 Farmer v. Dep’t of Corr., 346 Ga. App. 387, 394 (2) ( 816 SE2d 376 ) (2018) (punctuation omitted); see Woods v. Hall, 315 Ga. App. 93, 96 ( 726 SE2d 596 ) (2012) (“[A]n assertion of error followed by a case citation is not legal argument, which requires, at a minimum, a discussion of the appropriate law as applied to the relevant facts.” (punctuation omitted)). 16 See supra notes 13-14 & accompanying text. 11 We review de novo an allegedly erroneous jury instruction, which is “a legal question.”17 And in assessing the assertion that a jury instruction was erroneous, it m

2024Again, we disagree. 15 Farmer v. Dep’t of Corr., 346 Ga. App. 387, 394 (2) ( 816 SE2d 376 ) (2018) (punctuation omitted); see Woods v. Hall, 315 Ga. App. 93, 96 ( 726 SE2d 596 ) (2012) (“[A]n assertion of error followed by a case citation is not legal argument, which requires, at a minimum, a discussion of the appropriate law as applied to the relevant facts.” (punctuation omitted)). 16 See supra notes 13-14 & accompanying text. 11 We review de novo an allegedly erroneous jury instruction, which is “a legal question.”17 And in assessing the assertion that a jury instruction was erroneous, it m

2024Again, we disagree. 15 Farmer v. Dep’t of Corr., 346 Ga. App. 387, 394 (2) ( 816 SE2d 376 ) (2018) (punctuation omitted); see Woods v. Hall, 315 Ga. App. 93, 96 ( 726 SE2d 596 ) (2012) (“[A]n assertion of error followed by a case citation is not legal argument, which requires, at a minimum, a discussion of the appropriate law as applied to the relevant facts.” (punctuation omitted)). 16 See supra notes 13-14 & accompanying text. 11 We review de novo an allegedly erroneous jury instruction, which is “a legal question.”17 And in assessing the assertion that a jury instruction was erroneous, it m

2022See Ash v. State, 312 Ga. 771, 794-95 (5) (a) (865 SE2d 150) (2021) (Trial court’s failure to give portion of pattern charge on confession- corroboration was not plain error because Ash “has pointed to no precedent holding that the omission of this sentence from the pattern instruction constitutes error under these circumstances.”).

2022See Ash v. State, 312 Ga. 771, 794-95 (5) (a) (865 SE2d 150) (2021) (Trial court’s failure to give portion of pattern charge on confession- corroboration was not plain error because Ash “has pointed to no precedent holding that the omission of this sentence from the pattern instruction constitutes error under these circumstances.”).

2022See Rice v. State, 311 Ga. 620, 624 (1) (857 SE2d 230) (2021) (citing possibility that testimony of a co-defendant and another potential accomplice could be found “mutually corroborating” in concluding that the trial 5 At oral argument, Payne acknowledged that merely being an accomplice in the underlying drug transaction would not be enough to trigger the statute’s corroboration requirement in this case.

2022See Rice v. State, 311 Ga. 620, 624 (1) (857 SE2d 230) (2021) (citing possibility that testimony of a co-defendant and another potential accomplice could be found “mutually corroborating” in concluding that the trial 5 At oral argument, Payne acknowledged that merely being an accomplice in the underlying drug transaction would not be enough to trigger the statute’s corroboration requirement in this case.

2021See State v. Johnson, 305 Ga. 237, 238 (824 SE2d 317) (2019) (rejecting the State’s argument that “an [accomplice-corroboration] instruction is not clearly required where a witness other than the accomplice introduces an accomplice’s statement implicating defendant’s guilt”). 22 Appellant contends that because Marlon’s statements were (improperly) admitted at trial and the evidence clearly supported a finding that Marlon was an accomplice in the charged crimes, the trial court should have given the jury an instruction about the requirement of accomplice corroboration.

2021See State v. Johnson, 305 Ga. 237, 238 (824 SE2d 317) (2019) (rejecting the State’s argument that “an [accomplice-corroboration] instruction is not clearly required where a witness other than the accomplice introduces an accomplice’s statement implicating defendant’s guilt”). 22 Appellant contends that because Marlon’s statements were (improperly) admitted at trial and the evidence clearly supported a finding that Marlon was an accomplice in the charged crimes, the trial court should have given the jury an instruction about the requirement of accomplice corroboration.

2021It is not obligated to believe any witness, and it may accept or reject any portion of a witness’s testimony.” (punctuation omitted)). 11 See Garner v. State, 346 Ga. App. 351, 355 (1) ( 816 SE2d 368 ) (2018) (holding that corroborating evidence was not required to support defendant’s rape conviction); Glaze v. State, 317 Ga. App. 679, 681 (1) ( 732 SE2d 771 ) (2012) (“[T]he testimony of a single witness is generally sufficient to establish a fact[,] . . . [a]nd the General Assembly long ago removed the corroboration requirement from the rape statute.” (punctuation and footnote omitted)). 12 S

2021It is not obligated to believe any witness, and it may accept or reject any portion of a witness’s testimony.” (punctuation omitted)). 11 See Garner v. State, 346 Ga. App. 351, 355 (1) ( 816 SE2d 368 ) (2018) (holding that corroborating evidence was not required to support defendant’s rape conviction); Glaze v. State, 317 Ga. App. 679, 681 (1) ( 732 SE2d 771 ) (2012) (“[T]he testimony of a single witness is generally sufficient to establish a fact[,] . . . [a]nd the General Assembly long ago removed the corroboration requirement from the rape statute.” (punctuation and footnote omitted)). 12 S