Allan Traughber v. State

CourtCourt of Appeals of Georgia
DecidedOctober 30, 2025
DocketA25A1413
StatusPublished

This text of Allan Traughber v. State (Allan Traughber v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allan Traughber v. State, (Ga. Ct. App. 2025).

Opinion

FIFTH DIVISION MCFADDEN, P. J., HODGES and PIPKIN, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

October 30, 2025

In the Court of Appeals of Georgia A25A1413. TRAUGHBER v. THE STATE.

PIPKIN, Judge.

Appellant Allan Traughber challenges his 2023 convictions for child rape,

incest, and other crimes against his 7-year-old daughter G. T. and his developmentally

delayed 17-year-old niece T. T. Appellant contends that the evidence was statutorily

insufficient to support his conviction for incest against T. T. under OCGA § 24-8-823

due to the lack of evidence corroborating his confession and that he was denied the

effective assistance of counsel due to his trial counsel’s failure to conduct a thorough

and sifting cross-examination of the State’s witnesses. As explained below,

Appellant’s out-of-court confession that he committed incest against T. T. was

sufficiently corroborated by other evidence presented at trial, and he has failed to show either deficient performance or resulting prejudice from his counsel’s strategic

and tactical decisions regarding whether and how to cross-examine the State’s

witnesses. Accordingly, we affirm.

1. Appellant does not challenge the sufficiency of the evidence to support his

convictions for child rape, aggravated child molestation, aggravated sexual battery,

and incest against his daughter G. T. He also does not challenge the sufficiency of the

evidence to support his conviction for incest against his niece T. T. as a matter of due

process. See Jackson v. Virginia, 443 U.S. 307, 319 (III) (B) (99 SCt 2781, 61 LE2d

560) (1979); OCGA § 16-6-22 (a) (6) (“A person commits the offense of incest when

such person engages in sexual intercourse or sodomy, as such term is defined in Code

Section 16-6-2 [i.e., oral sex or anal sex], with a person whom he or she knows he or

she is related to by blood, by adoption, or by marriage as follows: [u]ncle and niece . . .

by virtue of adoption.”). Nor does he claim that the court erred in admitting into

evidence his video-recorded custodial interview by investigators Jason McCoy and

Nicholas Luke of the Toombs County Sheriff’s Office in which Appellant confessed

to committing incest against his niece T. T. by having sexual intercourse with her

when she was 14 years old. Instead, he contends that the evidence at trial was

2 insufficient to support his conviction for incest against T. T. because the State’s case

rested solely on his uncorroborated confession. See OCGA § 24-8-823 (“All . . .

confessions of guilt shall be received with great caution. A confession alone,

uncorroborated by any other evidence, shall not justify a conviction.”)1

At trial, Appellant testified that he “never had sex of any sort with [his] niece”

and claimed, “The reason I, I originally admitted to sleeping with [T. T.] was because

I figured that she’d be the next one on the wagon to file allegations against me

considering she didn’t like me.” Appellant argues that his confession to incest against

T. T. in his custodial interview, which was played for the jury at trial, was not

corroborated by any other evidence at trial as required by OCGA § 24-8-823 because

in her trial testimony, T. T. did not state that Appellant had vaginal sex with her.

However, OCGA § 24-8-823 “does not fix the amount of evidence necessary to

corroborate a confession but leaves the question of its corroborative sufficiency

entirely with the jury.” Gilder v. State, 219 Ga. 495, 497 (3) (133 SE2d 861) (1963).

1 Georgia’s current Evidence Code contains four provisions that directly address confessions by criminal defendants: OCGA § 24-1-104 (c), which prescribes the procedure for admitting confessions (“Hearings on the admissibility of confessions shall in all cases be conducted out of the hearing of the jury. . . .”), and OCGA §§ 24-8-823, 24-8-824, and 24-8-825, which provide the substantive law governing the admissibility and weight of confessions. 3 “The amount of evidence necessary to corroborate a confession is left entirely within

the province of the jury[,] and corroboration in any material particular satisfies the

requirements of the law.” Brown v. State, 198 Ga. App. 352, 353 (1) (401 SE2d 568)

(1991). See also Boone v. State, 321 Ga. 820, 826 (917 SE2d 78) (2025) (“When the

jury finds that a confession is corroborated, it need not find proof of guilt beyond a

reasonable doubt from evidence separate from and wholly independent of the

confession, and it instead may consider the confession along with other facts and

circumstance independent of and separate from it.” (citation and punctuation

omitted)); Baker v. State, 319 Ga. 456, 460 (1) (902 SE2d 645) (2024).

Appellant’s out-of-court confession that he committed incest against T. T. was

sufficiently corroborated by the following evidence at trial: G. T., who lived in the

same house as Appellant and T. T., testified that Appellant touched G. T.’s “no-

no’s,” meaning her vagina, with “[h]is no-no’s,” meaning his penis, and that when

he does that, it “[h]urts a lot.” T. T. testified that she has “bad memories” associated

with Appellant, that she “put those memories in . . . [a] black box” in her brain and

“lost that key,” and that she is “never opening the black box.” Courtney Anderson,

an attorney appointed as the children’s guardian ad litem, testified that “the very first

4 thing that [s]he noticed” when she met T. T. for the first time was that T. T. “would

hiss at [Anderson] if [Anderson] called [Appellant’s] name.” Anderson explained that

T. T. would “literally fangs out snarl” where “[y]ou could see her teeth.” Anderson

also testified that she was “aware of [T. T.’s] victimization as well as [G. T.’s].”

Heather Cowart, a licensed professional counselor who conducted a forensic interview

of T. T. at the Sunshine House Children’s Advocacy Center in Swainsboro in

December 2022, testified that T. T. described Appellant as a “jerk and a liar” and

talked about Appellant “doing inappropriate things with children in the room.”

Tonya Harris, the clinical director at Sunshine House, testified that at the time of trial

in August 2023, “chronologically [T. T. was] 17 years old, but from a developmental

standpoint, . . . [T. T. was] more along the lines of somewhere between like nine and

eleven years old.” Harris also testified that when she first met T. T. in January 2023,

T. T. was “disheveled, appearance unkempt, hair was not clean, clothes were loose

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Gilder v. State
133 S.E.2d 861 (Supreme Court of Georgia, 1963)
Lawrence v. State
690 S.E.2d 801 (Supreme Court of Georgia, 2010)
Smith v. State
782 S.E.2d 269 (Supreme Court of Georgia, 2016)
Romer v. State
745 S.E.2d 637 (Supreme Court of Georgia, 2013)
Baker v. State
750 S.E.2d 137 (Supreme Court of Georgia, 2013)
Washington v. State
755 S.E.2d 160 (Supreme Court of Georgia, 2014)
Brown v. State
401 S.E.2d 568 (Court of Appeals of Georgia, 1991)
Merritt v. State
310 Ga. 433 (Supreme Court of Georgia, 2020)
Patterson v. State
875 S.E.2d 771 (Supreme Court of Georgia, 2022)
Jiles v. State
910 S.E.2d 159 (Supreme Court of Georgia, 2024)
Baker v. State
902 S.E.2d 645 (Supreme Court of Georgia, 2024)
Boone v. State
321 Ga. 820 (Supreme Court of Georgia, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
Allan Traughber v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/allan-traughber-v-state-gactapp-2025.