Supreme Court of Georgia

Williams v. the Stat

February 7, 2023315 Ga. 490

Summary

The court affirmed Williams’s convictions, holding that admission of the cell-site location information did not constitute plain error because no controlling authority clearly required a warrant for electronically stored CSLI to identify the provider’s physical data location with greater particularity. The court also held that, even assuming an accomplice-corroboration instruction was required, its omission did not affect Williams’s substantial rights because Davis’s material testimony was extensively corroborated and cumulative of other evidence. The court further clarified that an unpreserved Fourth Amendment evidentiary challenge is subject to plain-error review absent affirmative waiver.