Summary
The Supreme Court of Georgia affirmed Christopher Bradshaw’s convictions for two malice murders and related offenses arising from a drug-deal shooting. The court held that the evidence, including accomplice testimony and corroborating physical and DNA evidence, was legally sufficient. It also upheld the admission of evidence concerning a prior Ohio murder under Georgia’s new Evidence Code for purposes including intent and motive.
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Practice areas
Questions Presented
- Whether the evidence was legally sufficient to support Bradshaw's convictions when the State's evidence included testimony from an accomplice and evidence of a prior murder.
- Whether the trial court erred by admitting evidence of Bradshaw's prior Ohio murder under OCGA § 24-4-404 (b) to prove intent, motive, and identity.
Holdings
- The evidence was sufficient for a rational jury to find beyond a reasonable doubt that Bradshaw committed the charged crimes.
- The independent evidence sufficiently corroborated Boykin's testimony under OCGA § 24-14-8.
- The trial court did not abuse its discretion by admitting evidence of the Ohio murder to prove intent and motive.
Key quotations
“It must, however, be independent of the accomplice testimony and must directly connect the defendant with the crime, or lead to the inference that he is guilty.” (8)
“Evidence of other crimes, wrongs, or acts shall not be admissible to prove the character of a person in order to show action in conformity therewith.” (9)
“For these reasons, we conclude that the trial court did not abuse its discretion by admitting evidence of the Ohio crime.” (13)
Factual background
Bradshaw arranged through his co-defendant, Michael Boykin, to purchase marijuana from Devonta Stembridge. During the transaction, Bradshaw shot Stembridge in the back of the head and also shot Dion Brice, who was in the vehicle. Ballistic, DNA, and clothing evidence connected Bradshaw to the shootings, and the murder weapon was recovered from his apartment. The State also introduced evidence that Bradshaw had previously shot and killed Jeffery Beans in Dayton, Ohio, after a drug-related dispute.
Procedural history
Bradshaw and Michael Boykin were jointly indicted in Clayton County, but their trials were severed and Bradshaw was tried first. A jury found Bradshaw guilty of eight counts, including two counts of malice murder, possession of a weapon during the commission of a felony, and criminal attempt to possess marijuana; the felony-murder verdicts were vacated, the aggravated-assault counts were merged, and the trial court directed a verdict on tampering with evidence. The trial court denied Bradshaw's amended motion for new trial, and he timely appealed to the Supreme Court of Georgia.