Willis v. Georgia
Annotate this CaseStephen Willis was convicted along with four co-defendants of crimes arising from the 2014 shooting death of Nicholas Hagood. On appeal, Willis contended: (1) the evidence was insufficient to sustain his convictions; (2) the trial court plainly erred by failing to instruct the jury that the testimony of an accomplice requires corroboration; and (3) his trial counsel was ineffective for allowing an exhibit to be introduced that included information about his prior encounters with law enforcement, not requesting a limiting instruction as to how the jury could consider that felony conviction, and failing to move to suppress the search warrant that yielded Willis’s phone records. The Georgia Supreme Court concluded the evidence was sufficient to support Willis’s convictions. Further, the failure to give an accomplice-corroboration jury instruction was not plain error, because even assuming the instruction should have been given, the failure to give it was not likely to have affected the outcome of the trial in light of the substantial evidence against Willis. Finally, Willis failed to establish that he received ineffective assistance of counsel at trial. "He has not shown that he was prejudiced by the introduction of the exhibit that showed his prior criminal history, and his counsel was not deficient for failing to move to suppress the search warrant because the warrant was supported by probable cause: the warrant application relied in part on a statement from a named informant that was against the informant’s penal interest." So judgment was affirmed.
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