Styles v. State

Michael Styles and his brother Derrick were convicted by a Brooks County jury for a home invasion robbery that left one victim, Alberto Lumens, dead and another robbed at gunpoint. Three accomplices testified that Styles helped plan the crime and served as the getaway driver, while Styles argued their testimony was uncorroborated and insufficient, that the trial judge mishandled a jury note and refused a requested robbery instruction, that the prosecutor improperly called him a devil in closing argument, and that his defense lawyer failed to investigate the case and should have sought a separate trial from his brother. The Supreme Court of Georgia found the accomplices corroborated each other and were backed by surveillance video and recorded phone calls, that the evidence showed only a completed armed robbery so no lesser robbery charge was required, that Styles showed no harm from any jury-note error, that the prosecutor's remarks were a fair response to defense arguments, and that his lawyer's strategy of shifting blame to more culpable co-defendants was reasonable. It affirmed the convictions.

The court held that testimony from multiple accomplices can corroborate each other and, combined with video and phone evidence, was sufficient to convict Styles; that no lesser robbery instruction was required because only the completed armed robbery was shown; and that his lawyer's strategic choices were not deficient performance.

The ruling reaffirms that accomplices can corroborate each other's testimony without independent evidence, that defendants must show actual harm from jury-communication errors, and that lawyers can reasonably choose not to seek severance when blaming co-defendants, guidance that shapes how Georgia trial and defense lawyers handle multi-defendant robbery and murder cases.

Affirmed

1. Under Georgia's corroboration rule for accomplice testimony (former OCGA § 24-4-8), a single accomplice's word isn't enough to convict, but corroborating evidence, even slight or circumstantial, from an independent source can support a conviction; here three accomplices corroborated each other and gas-station video and phone records backed their accounts.
2. Because the trial evidence showed only that Derrick completed an armed robbery with a gun and that Styles was a party to that crime, the court concluded no evidence supported a lesser robbery charge, so the trial judge did not err in refusing to instruct the jury on that lesser offense.
3. Reviewing the jury-note handling for plain error since Styles did not object at trial, the court found that even assuming the judge did not follow every required step for responding to jury questions, Styles never showed how following those steps more closely would have changed the outcome, so there was no reversible error.
4. On the prosecutor's use of the word 'devil' to describe Styles in closing argument, the court found Styles waived the issue by not objecting at trial, and separately concluded the remark was a fair response to the defense's own use of that language to attack the credibility of the State's witnesses.
5. Applying the two-part test for ineffective assistance of counsel, which requires showing both deficient performance and resulting harm, the court found Styles failed to specify what further investigation would have uncovered and found his lawyer's strategy of shifting blame to his brother and other more culpable participants, rather than seeking a separate trial, was a reasonable trial strategy that does not amount to deficient performance.

• felony murder conviction
• armed robbery
• accomplice testimony
• ineffective assistance of counsel
• jury communication