Summary
This per curiam opinion from the Supreme Court of Georgia affirms Quame Lamar Collins’s convictions for malice murder, felony murder, armed robbery, and related firearm offenses arising from a 2017 shooting. On appeal, Collins challenged the constitutional sufficiency of the evidence, the trial court’s denial of a mistrial motion concerning alleged gang affiliation, and the admission of hearsay statements. The court concluded that the evidence was constitutionally sufficient, that Collins waived his mistrial claim by declining a curative instruction, and that any hearsay error was harmless because it was cumulative of other properly admitted evidence.
Topics
Practice areas
Questions Presented
- Whether the evidence was constitutionally sufficient to support Collins's convictions.
- Whether Collins waived appellate review of the denial of his motion for a mistrial after evidence of alleged gang affiliation was introduced when he rejected the trial court's offer of a curative instruction.
- Whether recorded statements attributed to Collins and statements attributed to his mother were inadmissible hearsay, and whether any error in admitting them was harmless.
Holdings
- The evidence was constitutionally sufficient to support Collins's convictions because a rational trier of fact could find him guilty beyond a reasonable doubt, including as a party to the crimes even if another participant fired the fatal shots.
- Collins waived his right to challenge the denial of his motion for a mistrial because he rejected the trial court's offered curative instruction.
- The statements Collins made directly to Simmons were admissible as statements of a party opponent. Even if statements attributed to Collins's mother were inadmissible hearsay or lacked a sufficient basis for admission as adoptive admissions, any error was harmless because the information was cumulative of properly admitted evidence.
Key quotations
“When reviewing the sufficiency of the evidence as a matter of constitutional due process, we view the evidence in the light most favorable to the verdict and inquire whether a rational trier of fact could have found the defendant guilty beyond a reasonable doubt.” (321 Ga. at 217)
“Because Collins rejected the trial court’s offer of a curative instruction, he “waived his right to complain about the trial court’s denial of his motion for mistrial.”” (321 Ga. at 221)
“Thus, the trial court properly admitted those statements as statements by a party opponent.” (321 Ga. at 225)
“Thus, even assuming that the statements were inadmissible, any alleged error in admitting them was harmless.” (321 Ga. at 229)
Factual background
On January 23, 2017, two men entered Eddie Louis Grubbs's mobile home while Grubbs, Marshall Jordan, and Walter Smith were inside playing dominoes, and the men began shooting. Grubbs and Jordan died, and Smith was injured. Joyce Striggles Herndon identified Collins, whom she knew as “Fat Boy,” as one of the men who entered the home, and other evidence included eyewitness testimony, Collins's possession-related admissions as recounted by Tonya Simmons, and evidence concerning a vehicle and Collins's phone. The jury convicted Collins of the charged offenses.
Procedural history
A Burke County grand jury indicted Collins for two counts of malice murder, two counts of felony murder, armed robbery, multiple firearm offenses, aggravated assault, and possession of a firearm by a convicted felon. Following a bifurcated jury trial in June 2021, Collins was convicted on all counts and received consecutive sentences, including two life sentences without parole. His motion for new trial, as amended, was denied, and he appealed, challenging the sufficiency of the evidence, denial of a mistrial, and admission of hearsay. The Supreme Court of Georgia affirmed.