Hood v. State

Jamie Donnell Hood was convicted of 36 crimes, including the 2010 murder of Kenneth Wray and the 2011 murder of Athens-Clarke County Police Officer Elmer Christian during a manhunt after he kidnapped a man named Judon Brooks. Hood represented himself at trial. On appeal, he argued the State hid a deal it had with a witness named Quintin Riden, who recorded some of Hood's confessions, and that the trial judge should have told jurors a confession alone cannot support a conviction without other supporting evidence. He also argued the judge should have instructed jurors on an insanity-related defense for the officer shootings and that testimony about family photos on Officer Christian's patrol car computer was wrongly allowed. The Supreme Court of Georgia rejected every argument. It found that even if Riden had undisclosed deals with prosecutors, so much other evidence, including Hood's own recorded confessions, ballistics, and multiple witnesses, supported his guilt that the outcome would not have changed. It also found no evidence supported a delusional compulsion defense and that any error about the photos was harmless. The convictions and sentences stand.

The court held that even assuming the State suppressed evidence of a witness's cooperation deals and that a confession-corroboration instruction should have been given, neither error was likely to have changed the trial's outcome given the overwhelming independent evidence of Hood's guilt, including his own recorded confessions and ballistics matching him to the murder weapon.

The ruling shows Georgia courts will uphold convictions even when prosecutors fail to disclose a witness's cooperation deals, as long as independent evidence of guilt is strong. It also reaffirms that self-represented defendants bear the burden of requesting jury instructions or showing plain error.

Affirmed

1. The court applied the Brady rule, which requires prosecutors to disclose evidence favorable to a defendant, including deals with witnesses that could be used to challenge their credibility, and asked whether disclosure would have created a reasonable probability of a different outcome.
2. Even assuming a witness named Riden had undisclosed cooperation deals with state and federal prosecutors, the court found the jury already knew Riden had pled guilty to federal charges and had reason to cooperate, so the missing details would not have added much doubt about his credibility.
3. The court found Riden's testimony was largely duplicated by Hood's own recorded confession, testimony from six other witnesses, and ballistics evidence matching a shell casing in Hood's car to the gun that killed Wray, so any suppressed evidence about Riden was not material to the verdict.
4. On the confession-corroboration instruction, which tells jurors a confession alone cannot support a conviction, the court applied the plain-error standard requiring a defendant to show the missing instruction likely changed the outcome, and found Hood made multiple confessions to different witnesses that corroborated one another and were backed by independent evidence.
5. The court rejected the request for a delusional compulsion instruction, a defense requiring proof that a mental disease caused an uncontrollable urge to act in a way that would have been lawful if the imagined facts were true, because Hood offered no evidence of any mental disease and his own account showed his conduct would not have been lawful even under his imagined circumstances.
6. The court found any error in allowing testimony about family photos on the officer's patrol car computer was harmless because Hood admitted shooting the officer and offered no justification defense, and similar testimony had already been given without objection.

• murder conviction
• Brady violation
• police officer killed
• witness cooperation deal
• self-representation at trial