Supreme Court of Georgia
Armstrong v. State
December 21, 2020310 Ga. 598
Summary
The court affirmed Armstrong's convictions, holding that the gang-affiliation evidence was relevant and sufficiently probative of motive to be admitted under Rule 404 (b). The court declined to decide whether testimony about Internet photographs violated hearsay, best-evidence, or Confrontation Clause rules because any error was harmless, and it rejected Armstrong's unpreserved challenge to the missing limiting instruction under plain-error review. Armstrong also failed to establish prejudice from counsel's omission because the instruction's absence did not affect the trial's outcome.