Supreme Court of Georgia

White v. the State. — Bethel, J., Concurring

February 4, 2019305 Ga. 111

Summary

The concurrence agrees with the judgment but rejects the majority's suggestion that the plain-error inquiry may be reduced to three prongs for criminal evidentiary errors. It would resolve the case under the fourth prong because, although improperly admitted evidence may have affected the verdict, upholding the conviction did not seriously affect the fairness, integrity, or public reputation of the proceedings. The concurrence emphasizes that Georgia's plain-error framework requires separate satisfaction of all four prongs.