Supreme Court of Georgia

Clark v. State

January 18, 2023315 Ga. 423

Summary

The court affirmed Clark’s convictions, holding that the evidence was sufficient to prove he was a party to the felony murder and related firearm offense even though the evidence indicated that his accomplice fired the fatal shot. It also held that the trial court properly applied a totality-of-the-circumstances standard to Clark’s juvenile Miranda waiver, and clarified that the previously identified nine-factor framework is neither required nor exclusive. The court rejected Clark’s unpreserved jury-instruction claim under plain-error review and rejected both ineffective-assistance claims.