Sims v. State

321 Ga. 627
CourtSupreme Court of Georgia
DecidedMay 28, 2025
DocketS25A0058
StatusPublished
Cited by5 cases

This text of 321 Ga. 627 (Sims v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sims v. State, 321 Ga. 627 (Ga. 2025).

Opinion

321 Ga. 627 FINAL COPY

S25A0058. SIMS v. THE STATE. S25A0150. GLOVER v. THE STATE.

BETHEL, Justice.

Colton Jerrod Sims and Monte Glover were convicted of malice

murder and other crimes in connection with the shooting death of

DeCoby Barlow and the contemporaneous aggravated assault of

Landon Brown.1 Both Sims and Glover challenge the sufficiency of

1 The crimes occurred on December 8 to 9, 2018. In February 2019, a

Henry County grand jury indicted Sims, Glover, and co-defendant Jalon Edwards for malice murder (Count 1), felony murder predicated on aggravated assault (Count 2), two counts of aggravated assault (Counts 5 and 6), and two counts of possession of a firearm during the commission of a felony (Counts 9 and 10). Sims was separately indicted for felony murder predicated on possession of a firearm by a convicted felon (Count 3) and possession of a firearm by a convicted felon (Count 7); Glover was separately indicted for the same crimes (Counts 4 and 8). Sims, Glover, and Edwards were tried together before a jury in January and February 2020 and were found guilty on all counts. Edwards’ case is not part of this appeal. The trial court sentenced Sims and Glover to serve life in prison on Count 1, twenty years concurrent on Count 6, five years consecutive on their respective felon-in-possession counts, and five years consecutive on Count 9. The remaining counts merged or were vacated by operation of law. Sims and Glover separately filed timely motions for new trial, which were amended. Following evidentiary hearings, the trial court entered orders denying Sims’ and Glover’s motions, as amended, on November 22, 2023, and July 28, 2023, respectively. Sims and Glover then filed timely notices of appeal, the evidence supporting their convictions. Additionally, Sims raises

four claims of trial court error, and both Sims and Glover assert that

their trial counsel was constitutionally ineffective in various

respects. For the reasons that follow, we affirm.

1. Viewed in the light most favorable to the verdicts, the

evidence at trial showed the following. On the evening of December

8, 2018, Sims and his friend Colby Toles got into a dispute with

Glover and co-defendant Jalon Edwards at a nightclub. During the

ensuing scuffle between Toles and Edwards, Edwards brandished a

firearm, and the dispute moved outside. The group and several

patrons, including Barlow, likewise exited the building.

A witness, Chris Jackson, testified that he saw Sims, whom he

knew, fire several shots in the air near the club at the corner of the

building and that he thought Sims was “taking up” for Toles.

Jackson then heard shots being fired by another person.

Security guards outside the club observed Glover retrieve a

and their cases were docketed to this Court’s term beginning in December 2024 and submitted for a decision on the briefs.

2 firearm from his vehicle and then heard shots ring out from different

directions outside the club. Brown, one of the security guards, saw

several people with firearms, heard shots fired toward him and the

other security guards at the front of the club, and heard shots

returned between the front of the club and the adjacent building.

While fleeing the barrage of shots, Barlow was struck in the

crossfire, sustaining a fatal gunshot wound to his back.

During the investigation into the crimes, ballistics evidence

confirmed that shots were fired between the two locations. Police

ultimately recovered a Glock handgun belonging to Edwards, which

was determined to have fired the bullet that killed Barlow. A

detective obtained surveillance video showing the crimes, which was

played for the jury at trial, and which the detective testified showed

Edwards and Glover firing weapons. The jury also heard testimony

that one of the security guards, who was present during the crimes

and who knew Glover, reviewed the security footage of the incident

and observed Glover fire his weapon.

2. Sims and Glover first challenge the sufficiency of the

3 evidence supporting their convictions as a matter of constitutional

due process. When reviewing the sufficiency of the evidence as a

matter of constitutional due process, the proper standard of review

is whether any rational trier of fact could have found the defendant

guilty beyond a reasonable doubt of the crimes of which he was

convicted. Jackson v. Virginia, 443 U. S. 307, 319 (III) (B) (99 SCt

2781, 61 LE2d 560) (1979). This Court views the evidence in the

“light most favorable to the verdict, with deference to the jury’s

assessment of the weight and credibility of the evidence.” Hayes v.

State, 292 Ga. 506, 506 (739 SE2d 313) (2013) (citation and

punctuation omitted). “The jury’s verdicts will be upheld as long as

some competent evidence, even if contradicted, supports each fact

necessary to make out the State’s case.” Garcia-Solis v. State, 320

Ga. 754, 760 (1) (911 SE2d 673) (2025) (citation and punctuation

omitted). With these principles in mind, we address the appellants’

contentions in turn.

(a) Sims argues that the evidence against him was insufficient

to support his convictions for malice murder, aggravated assault,

4 and felon-in-possession because, he says, the evidence did not

support a finding that he was a party to the crimes.2 To that end, he

points to the “undisputed” fact that he did not fire the fatal shot and

evidence that he was unacquainted with his co-defendants. Sims

further complains that only one witness testified that he fired a

weapon, that the State failed to produce physical or video evidence

connecting him to the crime, and that the evidence against him was

circumstantial and inconsistent. We are not persuaded.

Sims was charged individually and as a party to the crimes.

OCGA § 16-2-20 (a) provides that “[e]very person concerned in the

commission of a crime is a party thereto and may be charged with

and convicted of commission of the crime.” “Conviction as a party to

a crime requires proof of a common criminal intent, which the jury

may infer from the defendant’s presence, companionship, and

2 Though Sims purports to challenge the sufficiency of the evidence on

all the charges of which he was found guilty, we confine our analysis to those crimes for which Sims was actually sentenced. See Milton v. State, 318 Ga. 737, 742 (2) n.5 (900 SE2d 590) (2024) (because appellant was not sentenced for charges that were vacated or merged, sufficiency claims related to those crimes were moot).

5 conduct with another perpetrator before, during, and after the

crimes.” Clark v. State, 315 Ga. 423, 427 (2) (883 SE2d 317) (2023).

We conclude that there was sufficient evidence from which the jury

could find that Sims was guilty of the crimes of which he was

convicted, at least as a party to the crimes.

As an initial matter, Sims’ complaints about the circumstantial

nature of the evidence3 and inconsistencies in the evidence do not

mean that the evidence was insufficient as a matter of constitutional

due process. See Anglin v. State, 312 Ga. 503, 506-507 (1) (863 SE2d

148) (2021) (“The fact that the evidence of guilt was circumstantial

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Bluebook (online)
321 Ga. 627, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sims-v-state-ga-2025.