Supreme Court of Georgia

McKinney v. State

March 5, 2024318 Ga. 566

Summary

The Court held that Rule 418 does not require the State to prove a nexus between a defendant’s other criminal act and gang membership or an intent to further gang interests before the act may qualify for admission under that rule. The Court also held that evidence admissible under Rule 418 remains subject to relevance requirements and Rule 403 balancing, so it affirmed the Court of Appeals’ judgment and remanded for that analysis. The Court rejected the argument that applying the rule according to its plain text would produce an impermissibly absurd result.