Jason Lee Durham v. State

CourtCourt of Appeals of Georgia
DecidedAugust 30, 2022
DocketA22A0868
StatusPublished

This text of Jason Lee Durham v. State (Jason Lee Durham 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
Jason Lee Durham v. State, (Ga. Ct. App. 2022).

Opinion

THIRD DIVISION DOYLE, P. J., REESE, J., and SENIOR APPELLATE JUDGE PHIPPS

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

August 30, 2022

In the Court of Appeals of Georgia A22A0867, A22A0868. DURHAM v. THE STATE.

DOYLE, Presiding Judge.

Following a consolidated trial on two indictments, Jason Lee Durham appeals

his convictions for two counts of possession of methamphetamine and possession of

an illegal weapon.1 Durham argues that the trial court plainly erred by failing to

instruct the jury as to accomplice testimony. For the reasons that follow, we reverse.

Viewed in the light most favorable to the verdict,2 the record shows that

Durham moved into the home of his then girlfriend, Brieanna Foster, in late 2015, and

1 The State dismissed a theft charge and a charge for possession of a schedule IV substance, and the trial court directed a verdict of acquittal as to a second theft charge. 2 See, e.g., Hawkins v. State, 304 Ga. 299, 300 (1) (818 SE2d 513) (2018). the two used methamphetamine together almost daily. In December 2016, officers

arrived at the home to gather information based on a report they received from the

drug task force. Foster and her children were preparing for a funeral, and Durham was

elsewhere on the property, possibly hunting or riding his four wheeler. After gaining

Foster’s consent, the officers searched the property, finding digital scales with

suspected methamphetamine residue, ownership of which Foster claimed. Foster was

arrested for possession of methamphetamine, which the officers found in an

outbuilding of the property where she testified that the pair frequently used the drug.

In addition to the methamphetamine, officers discovered a sawed-off shotgun, which

Foster testified belonged to Durham. Foster was frustrated that Durham did not come

back to the property while police were there arresting her, and she testified that he

believed she had called the police on him.

Near the end of January 2017, officers again came to Foster’s residence to

serve a warrant on Durham, who along with Foster and another man, had been using

methamphetamine the previous night. Officers escorted Foster and one of her children

out of the house before searching for Durham, who was in the basement. Foster

testified that Durham was checking for a leak under the bathroom, but an officer

testified that Durham repeatedly refused to come out after being called by officers.

2 Foster was arrested again in May 2017, at which time she stayed in jail for

approximately five months and entered a drug rehabilitation program for her

methamphetamine use. Foster was charged with many of the same crimes as Durham

in the instant cases,3 and she pleaded guilty to one charge of possessing

methamphetamine and had other charges nolle prossed the day before trial, receiving

probation and agreeing to testify against Durham.

An officer from the drug task force testified that in December 2016, the office

received an anonymous call regarding drug activity and a possible stolen car at the

home, which prompted them to visit the house, where Foster consented to the search.

The officer testified that there were multiple items of drug paraphernalia found

around the home in December, and some of it was discovered in Durham’s car and

with his personal paperwork.

At the close of evidence, the trial court instructed the jury that the testimony

of a single witness was sufficient to support a finding, but the jury was not instructed

as to the necessity of corroboration of a witness’s testimony if the witness was also

a co-conspirator, OCGA § 24-14-8. The trial court also instructed the jury on the law

3 Foster’s indictments do not include a charge for possession of the sawed-off shotgun.

3 of constructive possession and joint possession. The jury found Durham guilty of two

counts of possession of methamphetamine and one count of possession of an illegal

weapon, and the court sentenced Durham to probation. Durham then filed a motion

for new trial, which he later amended, and the trial court denied the motion, finding,

inter alia, that no plain error occurred when it failed to give the accomplice testimony

instruction. Durham appeals, presenting the same argument to this Court.

“In most instances, the testimony of a single witness is sufficient to establish

a fact under Georgia law. But that is not so in ‘felony cases where the only witness

is an accomplice.’”4

[Durham] did not object to the jury charges as given; thus any appellate review of the trial court’s instructions is for plain error only. . . . [T]o establish plain error in regard to jury instructions, the appellant must satisfy the following four prongs: First, there must be an error or defect — some sort of deviation from a legal rule — that has not been intentionally relinquished or abandoned, i.e., affirmatively waived, by the appellant. Second, the legal error must be clear or obvious, rather than subject to reasonable dispute. Third, the error must have affected the appellant’s substantial rights, which in the ordinary case means he

4 (Citation omitted.) Lewis v. State, 311 Ga. 650, 665 (4) (859 SE2d 1) (2021). See also State v. Johnson, 305 Ga. 237, 240 (824 SE2d 317) (2019), citing OCGA § 24-14-8; Stanbury v. State, 299 Ga. 125, 129-130 (2) (786 SE2d 672) (2016); Burns v. State, 342 Ga. App. 379, 383 (1) (803 SE2d 79) (2017).

4 must demonstrate that it affected the outcome of the trial court proceedings. Fourth and finally, if the above three prongs are satisfied, the appellate court has the discretion to remedy the error — discretion which ought to be exercised only if the error seriously affects the fairness, integrity or public reputation of judicial proceedings.5

“An accomplice is someone who shares a common criminal intent with the

actual perpetrator of a crime.”6 Because Foster was a testifying codefendant of

Durham, it was erroneous for the trial court to omit the accomplice testimony

instruction in light of the fact that it also instructed the jury that the testimony of a

single witness was sufficient to support a fact.7

By failing to give the required accomplice corroboration charge, the trial court impermissibly empowered the jury to find [Durham] guilty based

5 (Punctuation and citations omitted.) Palencia v. State, 313 Ga. 625, 627 (872 SE2d 681) (2022), quoting State v. Kelly, 290 Ga. 29, 33 (2) (a) (718 SE2d 232) (2011), and citing OCGA § 17-8-58 (b). 6 Stripling v. State, 304 Ga. 131, 136 (2) (816 SE2d 663) (2018), citing Williams v. State, 289 Ga. 672, 673 (715 SE2d 76) (2011). 7 See Palencia, 313 Ga. at 629-630 (explaining that even if there was independent corroborating evidence of the defendant, “the trial court’s failure to also charge the jury on the necessity of accomplice corroboration when charging it that the testimony of a single witness is sufficient to establish a fact was clear and obvious error”), collecting cases including, Doyle v. State, 307 Ga. 609, 613 (2) (b) (837 SE2d 833) (2020); Johnson, 305 Ga. at 238; Stanbury, 299 Ga. at 130 (2); Hamm v. State, 294 Ga.

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Related

Daugherty v. State
642 S.E.2d 345 (Court of Appeals of Georgia, 2007)
Sims v. State
701 S.E.2d 534 (Court of Appeals of Georgia, 2010)
State v. Kelly
718 S.E.2d 232 (Supreme Court of Georgia, 2011)
Williams v. State
715 S.E.2d 76 (Supreme Court of Georgia, 2011)
Hamm v. State
756 S.E.2d 507 (Supreme Court of Georgia, 2014)
Stanbury v. State
786 S.E.2d 672 (Supreme Court of Georgia, 2016)
Burns v. the State
803 S.E.2d 79 (Court of Appeals of Georgia, 2017)
Stripling v. State
816 S.E.2d 663 (Supreme Court of Georgia, 2018)
Parks v. State
818 S.E.2d 502 (Supreme Court of Georgia, 2018)
Hawkins v. State
818 S.E.2d 513 (Supreme Court of Georgia, 2018)
State v. Johnson
824 S.E.2d 317 (Supreme Court of Georgia, 2019)
Dickerson v. State
718 S.E.2d 564 (Court of Appeals of Georgia, 2011)
Doyle v. State
837 S.E.2d 833 (Supreme Court of Georgia, 2020)
Lewis v. State
859 S.E.2d 1 (Supreme Court of Georgia, 2021)
Palencia v. State
872 S.E.2d 681 (Supreme Court of Georgia, 2022)
Harris v. State
313 Ga. 225 (Supreme Court of Georgia, 2022)

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Bluebook (online)
Jason Lee Durham v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jason-lee-durham-v-state-gactapp-2022.