In the Supreme Court of Georgia

Decided: June 21, 2021

S21A0267. HOOD v. THE STATE.

 LAGRUA, Justice.

Appellant Jamie Donnell Hood appeals his 2015 convictions on 

a total of 36 counts charging him with murder, aggravated assault, 

kidnapping, carjacking, and other offenses. The charges arose from 

the December 2010 shooting death of Kenneth Omari Wray and a

series of crimes in March 2011 that resulted in the death of AthensClarke County Police Officer Elmer Christian. With regard to his 

convictions for the Wray murder, Appellant contends that (1) the 

State violated Brady v. Maryland, 373 U. S. 83 (83 SCt 1194, 10 

LE2d 215) (1963), by failing to disclose material impeachment 

evidence with regard to a key State’s witness; (2) the trial court 

erred by failing to give a jury instruction on the necessity of 

corroborating a confession; and (3) the cumulative harm of these two 
2

errors requires reversal. With regard to his convictions for the 

murder of Officer Christian, Appellant contends that the trial court 

erred by (1) failing to instruct the jury on the defense of delusional 

compulsion and (2) admitting testimony from a responding officer 

about images of Officer Christian’s family he saw on the on-board 

laptop computer in Officer Christian’s patrol car. We discern no 

reversible error, so we affirm.1

 1 Appellant was indicted by a Clarke County grand jury in June 2011, 

and was subsequently re-indicted in March 2014, on a total of 70 counts, which 

included malice murder (2 counts); felony murder (4 counts); attempted 

murder (1 count); aggravated assault upon a peace officer (3 counts); 

aggravated assault (15 counts); armed robbery (2 counts); kidnapping with 

bodily injury (1 count); kidnapping (11 counts); false imprisonment (10 counts); 

hijacking a motor vehicle (2 counts); burglary (1 count); possession of a firearm 

by a convicted felon (2 counts); possession of a firearm by a convicted felon 

during the commission of a crime (15 counts); and possession of a knife during 

the commission of a crime (1 count). The State filed a notice of intent to seek 

the death penalty for the murders of Wray and Christian. 

Approximately 15 months before trial, Appellant sought leave to 

represent himself. Following a hearing in accordance with Faretta v. 

California, 422 U.S. 806 (95 SCt 2525, 45 LE2d 562) (1975), the trial court 

granted Appellant’s motion, and Appellant represented himself at trial, with 

attorneys from the Capital Defender’s Office acting as standby counsel. 

Appellant’s jury trial commenced in June 2015. After nearly a month, at the 

conclusion of the guilt-innocence phase, the jury found Appellant guilty on 36 

of the 70 counts, including all counts associated with the shootings of Wray 

and Christian. These counts included, as to Wray, malice murder, two counts 

of felony murder, one count of aggravated assault with a deadly weapon, one 

count of firearm possession by a convicted felon, and one count of firearm 

possession during the commission of a crime; as to Christian, the counts 
3

The evidence at trial2 showed that Appellant was involved in 

the drug trade and had been supplying an associate, Kenyatta 

Campbell, with marijuana from a third party in Atlanta. At some 

 

included malice murder, two counts of felony murder, one count of aggravated 

assault upon a peace officer with a deadly weapon, one count of firearm 

possession by a convicted felon, and one count of firearm possession during the 

commission of a crime. In the penalty phase, the jury declined to impose a 

death sentence and recommended sentences of life in prison without the 

possibility of parole for the murder of Christian and life with parole for the 

murder of Wray. On July 24, 2015, the trial court sentenced Appellant in 

accordance with the jury’s recommendations and, with regard to the remaining 

offenses, Appellant was sentenced to three additional consecutive terms of life 

without parole plus 300 consecutive years in prison. 

On August 12, 2015, after the appointment of appellate counsel, 

Appellant filed a timely motion for new trial, which was amended in September 

2019 and January 2020. A hearing on the motion was held on January 29, 

2020. Shortly thereafter, Appellant filed a Motion to Reopen the evidence, 

seeking to supplement the record with new evidence in support of his Brady

claim. On April 29, 2020, the trial court entered an order granting in part the 

Motion to Reopen the evidence, permitting the admission of certain documents 

into the record, and denying the motion for new trial. On May 22, 2020, 

Appellant filed a notice of appeal, and the case was docketed to the term of this 

Court beginning in December 2020. Appellant initially requested oral 

argument but later withdrew that request, and the appeal was thereafter 

submitted for a decision on the briefs. 

2 Because Appellant does not challenge the sufficiency of the evidence to 

support his convictions, and because this case involves an assessment of the 

harm of alleged trial court error, we present the evidence as jurors reasonably 

would have viewed it, rather than in the light most favorable to the verdicts. 

See Davenport v. State, 309 Ga. 385, 399 (846 SE2d 83) (2020) (announcing

that this Court will no longer routinely consider sufficiency sua sponte in nondeath penalty cases); Hampton v. State, 308 Ga. 797, 802 (2) (843 SE2d 542)

(2020) (“In determining whether an error was harmless, we review the record 

de novo and weigh the evidence as we would expect reasonable jurors to have 

done so.” (Citation and punctuation omitted.)).
4

point before the crimes, Campbell began bypassing Appellant by 

purchasing directly from the source, angering Appellant. 

On the evening of December 28, 2010, Wray, an associate of 

Campbell, was shot outside the Athens home Wray shared with his 

mother, Ruby Jordan. Jordan testified that on the night of the 

shooting, she was dozing in her bedroom when she heard a knock or 

slam on the door and then another loud noise and her son calling for 

her. She then heard what sounded like firecrackers. Jordan peeked 

out the door and saw someone run from her driveway and, believing 

it was Wray, returned to her bedroom. A few minutes later, a friend 

of Wray came to the door, looking for Wray, and then saw him lying 

in the driveway.

The friend, Billy Howington, testified that he had arranged to 

buy marijuana from Wray on the night of December 28. Shortly 

before arriving at Wray’s home, he texted Wray that he was 

approaching. When Howington arrived, he parked his car in front 

of the house and waited for Wray to come out. Wray did not appear 

and did not return Howington’s texts or calls. Finally, Howington 
5

went to the door, and as he was talking to Jordan he realized Wray 

was lying in the driveway. 

A neighbor of Jordan, Mike Barnett, came outside after 

hearing a loud noise from the direction of Jordan’s home and saw 

Wray’s body in the driveway. As he was dialing 911, Barnett was 

approached by a police officer patrolling nearby, and emergency 

responders were dispatched. Wray had sustained multiple gunshot 

wounds, including one through his neck, and died after being 

transported to the hospital. 

At the scene, investigators recovered six .40-caliber shell 

casings. Interviews with Howington and another neighbor indicated 

that the shooter was a black male. Appellant was not identified as 

a suspect at the time.

Some three months later, on March 22, 2011, Judon Brooks, an 

associate of Wray and Campbell, went to Appellant’s home to inspect 

some marijuana. Brooks testified that, shortly after he arrived, 

Appellant and three masked men with firearms surrounded him, 

and one of the men began tying him up with zip ties. Appellant 
6

demanded that Brooks tell him Campbell’s whereabouts. When 

Brooks replied that he did not know, Appellant brandished a knife 

and threatened to kill him. The men put duct tape over Brooks’ 

mouth, covered his face, and put him in the trunk of Appellant’s car. 

Appellant drove away with Brooks in the trunk. After managing to 

break his hands free, Brooks opened the trunk latch and escaped 

when the car came to a stop. An acquaintance of Brooks who 

happened to be driving in the same vicinity saw him in the street 

seeking help and summoned him to his car. Brooks called 911, and 

a “be on the lookout” notice (BOLO) was issued for Appellant. 

In the meantime, Appellant had abandoned his car and called 

his brother, Matthew Hood, to pick him up. Athens-Clarke County 

Police Officer Tony Howard testified that he was patrolling the area 

in response to the BOLO. He recognized Matthew driving and 

flagged him down. When Matthew stopped, Officer Howard saw a 

man he recognized as Appellant exit Matthew’s car and run towards 

the driver’s side of Officer Howard’s patrol car. Officer Howard 

grabbed Appellant through his open window, but Appellant broke 
7

free, then turned and shot Officer Howard in the face and the back. 

The responding EMT testified that when he arrived on the scene, 

Officer Howard’s gun was still in the holster on his belt. 

Appellant continued running and came upon Officer 

Christian’s patrol car. Two witnesses saw Appellant run past the 

car and shoot twice through the driver’s side window. Officer 

Christian, who at the time was talking on his phone, was struck by 

both bullets. By the time emergency responders arrived, Officer 

Christian was deceased.

Continuing to run, Appellant approached a stopped car, in 

which Deborah Lumpkin was sitting. Lumpkin testified that 

Appellant, who was armed with a gun, got in the passenger seat and 

told her that he was running from the police and needed her to drive. 

She complied. After a short time, Appellant, whom Lumpkin 

described as calm and focused, instructed her to stop and get out. 

Appellant drove off and later abandoned the car, continuing his 

escape on foot. 

The manhunt for Appellant proceeded into the following day 
8

and night. At approximately 1:00 a.m. on March 24, Appellant went 

to the home of Darius Lanier, a longtime acquaintance, who supplied 

Appellant with food and clothing. Lanier testified that, during 

Appellant’s time at his home, Appellant admitted to shooting the 

two police officers. Appellant also told Lanier that he had killed 

Wray because Wray would not tell him where he could find 

Campbell. Appellant left at around 4:00 a.m. Later that morning, 

Lanier reported Appellant’s visit to his probation officer, who 

contacted the police. 

After leaving Lanier’s home, Appellant found his way to the 

Athens subdivision of Creekstone, where he gained entry into the 

home of Chayandre Bess and Mandrell Hull, also acquaintances of 

Appellant. Bess’s 13-year-old cousin, who was living with Bess and 

Hull at the time, testified that, as she prepared to leave for school 

on the morning of March 24, Appellant approached her outside the

home, brandished a gun, and ordered her to let him inside. Bess, 

Hull, and others in the home testified that Appellant forced them 

into a single room, then barricaded them in the home and held them 
9

hostage until the following evening, when he surrendered to the

police.3 

During his time in the Creekstone home, Appellant made 

several incriminating statements about the murder of Wray, 

kidnapping of Brooks, and shootings of Officers Howard and 

Christian. These witnesses testified that Appellant said he had shot

Wray when Wray would not tell him where Campbell lived and that 

Appellant described specifically how Wray had called for his mother 

before being killed.4 Appellant also told these witnesses that he had

 3 Appellant’s conduct in gaining entry to the home and in remaining 

there until his surrender was the subject of numerous counts in the indictment 

(31 in total) charging Appellant with burglary, kidnapping, false 

imprisonment, and aggravated assault. Several of the purported hostages 

were acquaintances of Appellant and knew Brooks, Campbell, and Wray. 

There was testimony that some of these purported hostages were permitted to 

leave the home for specific purposes, under threat of harm to the others if they 

went to the police or did not return, and that some of them had arrived at the 

home after Appellant. There was also testimony that Appellant slept for some 

period of time while in the home and that Appellant snorted cocaine and 

smoked marijuana with some of the purported hostages during the episode. 

Appellant testified that he was allowed in the home without any coercion and 

that he asked the home’s occupants to help him surrender to the police so they 

could claim the $50,000 in reward money being offered for his capture. 

Appellant was ultimately acquitted on all of the counts related to his conduct 

at the Creekstone home. 4 In cross-examining several of the Creekstone witnesses, Appellant 

attempted to establish that they were motivated to implicate him in the 
10

kidnapped Brooks for the same reason and had intended to kill him 

as well. Appellant also said that, while he was sorry for killing 

Officer Christian, he was glad he had shot Officer Howard, with 

whom he had a history of ill will. In reference to the gun he used to 

shoot Officers Howard and Christian, Appellant remarked, “[I]f you 

think this one’s pretty, you should have see[n] the one I killed Omari 

[Wray] with.” Many of Appellant’s statements about the crimes 

were surreptitiously recorded by one of the Creekstone witnesses,

Quintin Riden, and the recordings were played for the jury at trial.5 

Also while at the home, Appellant had phone conversations 

 

unsolved Wray murder by the desire to avoid possible prosecution for 

harboring a fugitive or to avert suspicions that some of them may have assisted 

Appellant in the abduction of Brooks. In his cross-examination of one of these 

witnesses, Appellant elicited that the witness had not told the police in her 

interview immediately after Appellant’s surrender that he had admitted to the 

Wray murder, and he asked whether she felt “any type retaliation that [she] 

might be put in jail for harboring a fugitive.” She responded that she had not, 

but she admitted that investigators “may have” asked about their participation 

in the Brooks kidnapping.

5 In his cross-examination of Riden, Appellant repeatedly asked Riden 

whether, after telling investigators about these recordings, he had initially 

refused to hand over his cell phone to investigators, to which Riden replied that 

he did not remember. Riden also admitted on cross-examination that 

investigators asked him whether he had participated in the Brooks 

kidnapping.
11

with both Brooks and Campbell. Brooks testified that Appellant told 

him, “B**ch, you better be lucky you got away. . . . I was going to kill 

your b**ch a** just like I did your boy”; Brooks believed Appellant’s 

statement was a reference to Wray’s murder. In Appellant’s 

conversation with Campbell, which Riden overheard and testified 

about, Appellant told Campbell that the reason he killed Wray was 

“because yo’ b**ch a** was hiding out. You got [Wray] killed because 

I couldn’t find you.” 

Shortly after his surrender on March 25, Appellant was 

interviewed by investigators and admitted that he had shot Officers 

Howard and Christian. He wrote a letter of apology to Officer 

Christian’s family, telling them that “I just seen [Christian] at the 

wrong time in the wrong situation.” The video recording of 

Appellant’s interview was played for the jury, and the letter was 

read aloud at trial. 

The State also offered audio recordings of two police interviews 

with Lanier, both of which were played for the jury. In the first 

interview, conducted on March 24, 2011, Lanier told the detective 
12

that Appellant admitted he had shot two police officers and hijacked 

a woman’s car and said he wanted to kill Campbell before he turned 

himself in. Lanier also told the detective that Appellant said he had 

killed Wray. In the second interview, conducted in April 2011, 

Lanier again stated that Appellant admitted to killing the officers 

and to killing Wray; that Appellant said he had gotten rid of the gun 

with which he had killed Wray; and that he had killed Wray because 

Wray would not reveal Campbell’s whereabouts.

The State also offered testimony from a GBI firearms examiner

that a .40-caliber shell casing, found in a search of Appellant’s car, 

was fired from the same gun as that used to shoot Wray. Additional 

testimony established that Wray had been shot seven times, but that 

only six shell casings were recovered from the scene. The firearms 

examiner also testified that the gun used to kill Wray was not the 

same gun used in the police shootings. 

Appellant testified in his own defense. He maintained that he 

was not involved in Wray’s murder and told the jury that the shell 

casing found in his car was the vestige of an armed robbery of which 
13

he had been a victim, in which the assailant’s gun had discharged in 

his car during their struggle. Appellant also claimed that the Brooks 

kidnapping incident was actually initiated by Brooks, when Brooks 

showed up at his house with two men, threatening to kill him. 

Appellant claimed it was only in response that he and his associates 

tied Brooks up and drove away with him. Appellant testified further 

that, when he was fleeing after the Brooks kidnapping and 

encountered Officers Howard and Christian, he heard the voice of 

his deceased brother – who had been killed by a police officer –

telling him, “Don’t let them do you like they done me.” Appellant 

testified that he continued running “out of fear. I’m running trying 

to get away. I’m running not to kill. I’m running to get away from 

them. They fixing to kill me, man.” 

1. In his first enumeration of error, Appellant contends that 

the State violated his due process rights by failing to disclose 

material impeachment evidence relating to Riden, the witness from 

the Creekstone home who recorded Appellant’s statements. See 

Brady, 373 U. S. at 87 (“[T]he suppression by the prosecution of 
14

evidence favorable to an accused upon request violates due process 

where the evidence is material either to guilt or to punishment[.]”); 

see also Giglio v. United States, 405 U. S. 150, 153 (92 SCt 763, 31 

LE2d 104) (1972) (impeachment evidence affecting reliability of 

witness testimony falls within the Brady rule). Appellant claims 

that this violation requires the reversal of his convictions related to 

Wray’s murder.

Riden testified at trial about having been summoned to the 

Creekstone home on March 24 by his friend, Hull, “to make a drug 

transaction.” According to Riden, he and his young son arrived at 

the home to find Appellant, whom he knew through his sister and 

cousin, holding Hull, Bess, and others hostage; Riden and his son

thus became hostages as well. Riden testified about statements 

Appellant made regarding the shootings of the officers, the murder 

of Wray, and the kidnapping of Brooks. Specifically, Riden testified 

that Appellant said he was sorry he had killed Officer Christian; 

that he wished he had killed Officer Howard instead; and that “the 

reason he did all this [was] because Judon [Brooks] and Ken 
15

Campbell . . . . went behind his back and started dealing with 

somebody that he was dealing with on the drug level.” With regard 

to Wray’s murder, Riden testified that Appellant said he went to 

Wray’s mother’s house and

ran up on Omari [Wray] and tell him, “Tell me where Ken 

at.” Omari refused to tell him where Ken was . . . so he 

said he shot him. Omari started screaming, making 

noises, and he shot him again. He said he seen Omari’s 

mama coming out to the door, and he didn’t want to shoot 

the old lady, but if she did, he would have shot her, too. 

And then he just fled.

Riden also testified about overhearing Appellant’s phone 

conversation with Campbell, in which Appellant told Campbell he 

was the reason Wray had been killed. Riden then testified about 

using his cell phone to secretly record Appellant making admissions 

about killing Wray. After authenticating the recordings, Riden 

testified as they were played for the jury, providing context and 

clarifying portions of the recordings that were difficult to 

understand.

At the beginning of Riden’s direct testimony, the prosecutor 

elicited that Riden was at the time under indictment on federal 
16

charges. Riden testified that he had pled guilty to cocaine 

distribution, was awaiting sentencing, and faced a sentence in the 

range of 84 to 105 months. The State tendered a certified copy of 

Riden’s indictment, filed in May 2014, charging him with two counts 

of cocaine distribution, one count of conspiracy to possess cocaine 

with the intent to distribute, and one count of possession of a firearm 

during a drug trafficking crime.6 The State also tendered a certified 

copy of Riden’s September 2014 plea agreement, in which Riden 

agreed to plead guilty to one of the cocaine distribution charges and 

to cooperate fully with law enforcement by giving complete and 

truthful statements regarding the federal charges and “any and all 

criminal violations about which [he] has knowledge or information.” 

Under the agreement, the prosecutor would consider such 

cooperation, if “completed prior to sentencing,” in determining 

whether a downward departure from the advisory sentencing range 

would be recommended. Also included among the State’s exhibits 

 6 Riden also testified that he was “originally arrested,” before going into 

federal custody, for cocaine possession, firearm possession by a felon, and a 

parole violation; there was no follow-up questioning regarding these charges. 
17

were two motions to continue sentencing, from December 2014 and 

June 2015, respectively, citing “ongoing matters that need to be 

resolved prior to sentencing.” On cross-examination, Riden denied 

that his trial testimony was in any way related to his federal 

sentencing and testified that he was motivated to testify because 

Appellant held him and his family hostage. 

In the course of preparing Appellant’s motion for new trial, 

appellate counsel learned that, at Riden’s sentencing approximately 

one month after the conclusion of Appellant’s trial, Riden was 

sentenced to 25 months in prison plus three years of supervised 

release. As reflected in the transcript from the federal sentencing 

hearing,7 the prosecutor moved for a downward departure based on 

Riden’s “significant” cooperation in Appellant’s case; the trial judge 

noted that Riden’s cooperation in Appellant’s case was “far beyond 

what [he] normally s[aw]” and told Riden that, for this reason, he 

had decided to “substantially reduce[ ] the sentence.”

 7 This transcript was admitted in the record by the trial court’s partial 

grant of Appellant’s Motion to Reopen. See footnote 1, above.
18

In the course of investigating the resolution of Riden’s federal 

charges, appellate counsel also discovered that, at the time of trial,

Riden had for more than a year been facing felony charges in 

Athens-Clarke County for cocaine possession and other crimes.8 

There had been no mention of these state-level charges at trial, and 

the State does not dispute that it never made Appellant aware of 

these charges. Documents from the record in that proceeding reflect 

that, in September 2015, these charges were nolle prossed pursuant 

to a motion filed by the State, which cited both Riden’s recent federal 

sentencing and his assistance to the State in Appellant’s case.

Appellant contends that the dismissal of Riden’s state-level 

charges and the leniency in his federal sentencing, both of which 

were explicitly tied to his cooperation in Appellant’s case, are

evidence of express agreements Riden made with the State and with 

federal prosecutors, which the State was obligated to have disclosed 

 8 In Appellant’s brief here, his counsel represent that they discovered the 

existence of these charges “by chance alone,” while investigating the federal 

charges. Documents from the record in Riden’s state prosecution were 

admitted in the record here as part of the trial court’s partial grant of the 

Motion to Reopen.
19

to Appellant under Brady and Giglio. Appellant contends that these 

agreements significantly undercut Riden’s credibility by exposing 

strong incentives for him to assist the State in its prosecution of 

Appellant and that, because of the significance of Riden’s testimony,

Appellant’s inability to use this evidence to impeach Riden deprived 

him of due process under Brady and Giglio.

It is well settled that

“[t]he suppression by the prosecution of evidence 

favorable to an accused upon request violates due process 

where the evidence is material either to guilt or to 

punishment, irrespective of the good faith or bad faith of 

the prosecution.” Brady v. Maryland, 373 U. S. at 87. 

This includes the suppression of impeachment evidence 

that may be used to challenge the credibility of a witness. 

See Giglio v. United States, 405 U. S. 150, 154-155 (92 SCt 

763, 31 LE2d 104) (1972).

State v. Thomas, Case No. S21A0324, 2021 WL 1724970, at *5-6 (3) 

(decided May 3, 2021) (citation omitted). Accordingly, the State is 

obligated to reveal any agreement, even an informal one, with a 

witness regarding criminal charges pending against the witness. 

See id. at *6 (3). To prevail on a Brady claim, a defendant must show 

that 
20

the State possessed evidence favorable to the defendant; 

[the] defendant did not possess the evidence nor could he 

obtain it himself with any reasonable diligence; the 

prosecution suppressed the favorable evidence; and had 

the evidence been disclosed to the defense, a reasonable 

probability exists that the outcome of the proceeding 

would have been different.

Id. (citation and punctuation omitted). Accord Schofield v. Palmer, 

279 Ga. 848, 852 (2) (621 SE2d 726) (2005). On appeal, a trial court’s 

factual findings on a Brady claim are reviewed under a clearly 

erroneous standard, and its application of the law to the facts is 

reviewed de novo. See Thomas, 2021 WL 1724970, at *6 (3). 

Here, in considering Appellant’s motion for new trial, the trial 

court assumed for the sake of argument that the evidence 

established that Riden had made deals to testify against Appellant 

with both the State and federal prosecutors and that such deals were 

suppressed by the State. Even assuming those facts to be true, the 

trial court held that Appellant had failed to establish a reasonable 

probability that, had this evidence been made available to 

Appellant, the outcome of his trial would have been different. In the 

trial court’s view, Appellant was unable to establish the 
21

“materiality” of the suppressed evidence because of the quantum 

and strength of the other evidence against Appellant, independent 

of Riden’s testimony. We agree with the trial court.

In order to show materiality, a defendant need not show that 

he would have been acquitted had the suppressed evidence been 

disclosed; rather, he need only show that the suppression of the 

evidence “undermines confidence in the outcome of the trial.” 

Schofield, 279 Ga. at 852-853 (3) (citation and punctuation omitted). 

In determining materiality, the court must examine the suppressed 

evidence in the context of the entire record. See Turner v. United 

States, __ U. S. __ (II) (A) (137 SCt 1885, 1893, 198 LE2d 443) (2017). 

Thus, we have held that the materiality element was established 

where the suppressed evidence would have impeached the testimony 

of the only witness who testified that the defendant confessed. See

Danforth v. Chapman, 297 Ga. 29, 30-32 (2) (771 SE2d 886) (2015). 

Likewise, evidence was material where it would have undercut the 

credibility of the only witness who “provided full insight into” the 

alleged motive for the crime, and whose testimony “[was] not 
22

duplicated elsewhere in the record.” Byrd v. Owen, 272 Ga. 807, 811 

(1) (536 SE2d 736) (2000). See also Thomas, 2021 WL 1724970, at 

*8-9 (3) (c) (materiality was shown where suppressed evidence 

would have impeached a witness whose testimony was highly 

corroborative of that of the defendant’s accomplice, whose testimony 

was significantly impeached). On the other hand, where there is 

strong evidentiary support for the defendant’s conviction apart from 

the testimony of the witness whose credibility would have been 

affected by the suppressed evidence, materiality may not be

established. See Strickler v. Greene, 527 U. S. 263, 292-296 (IV) (119 

SCt 1936, 144 LE2d 286) (1999). 

Here, we note first that the jury was apprised of the fact that 

Riden had pled guilty to his federal charges, that his plea agreement 

required him to cooperate in other criminal cases about which he 

had knowledge, and that the prosecution was obligated to consider 

such cooperation in its sentencing recommendations. Thus, while 

the full scope of Riden’s possible incentives to cooperate with the 

State was not made known to the jury, the jury was nonetheless 
23

aware that there was reason to regard his testimony with 

skepticism. See Rhodes v. State, 299 Ga. 367, 369-370 (2) (788 SE2d 

359) (2016) (materiality lacking where jury did not know about 

specific terms of witnesses’ plea deals but was made aware of their 

guilty pleas). 

Moreover, although Riden’s testimony was undeniably helpful 

to the State, it was largely cumulative of other evidence. First, the 

jury heard the recordings of Appellant’s own statement in which he 

discussed the Wray murder. While it is true that these recordings 

were made by Riden, they were made prior to, and shared with 

investigators in the immediate aftermath of, Appellant’s surrender 

in March 2011, years before Riden was charged in either the federal 

or the state case. In addition to Appellant’s own statement, there 

was testimony from six of the Creekstone witnesses – not including 

Riden – about Appellant’s admissions about Wray’s murder. 

Though all six of these witnesses were relatives of Riden,9 there were 

 9 Specifically, these witnesses included Riden’s wife, his mother-in-law 

and her husband, his sister-in-law and brother-in-law, and his wife’s niece.
24

additional witnesses, not associated with the Creekstone home and 

not related to Riden, who also testified that Appellant made 

incriminating statements about Wray’s murder. Specifically, Lanier 

testified that Appellant confessed to killing Wray, and Brooks 

testified that he understood Appellant’s statement about “killing 

[his] boy” to be a reference to Wray’s murder. All of the accounts of 

Appellant’s incriminating statements were consistent in describing 

his motive for the killing, and some included details about the 

murder – such as the description of Wray calling for his mother –

that were consistent with Wray’s mother’s testimony.10 Finally, the 

ballistics evidence strongly supported the conclusion that Appellant 

was responsible for Wray’s murder, because the .40-caliber cartridge 

casing found in Appellant’s car was confirmed to have been fired 

from the gun that killed Wray, and, although Wray was shot seven 

times, only six cartridge casings were recovered at the scene.

 10 In addition, at least two witnesses testified that Appellant said he had 

gotten rid of the gun he used in Wray’s murder, which was consistent with the 

firearm examiner’s testimony that Wray had been killed with a different gun 

than that used in the shootings of the officers.
25

In summary, examining the purportedly suppressed evidence 

in the context of the entire record, we conclude that there is not a 

reasonable probability that the jury would have reached any

different verdict had it been aware of Riden’s state-level charges or 

any additional information regarding any formal or informal 

agreements between Riden and either the State or federal 

prosecutors. The jury was already aware of Riden’s possible motive 

to assist the State in order to gain favor with federal prosecutors, 

and the alleged additional impeachment material would not have 

been likely to make a significant impact on the jury, particularly in 

light of the many witnesses who gave testimony similar to Riden’s 

and the independent evidence of Appellant’s guilt. Accordingly, 

Appellant’s Brady claim is without merit. 

2. Appellant next contends that the trial court committed plain 

error by failing to instruct the jury on the statutory requirement 

that a confession must be corroborated to support a conviction. See 

OCGA § 24-8-823 (“A confession alone, uncorroborated by any other 

evidence, shall not justify a conviction.”). Appellant contends that, 
26

because his confessions were critical to the State’s case with regard 

to Wray’s murder, the trial court’s failure to give a confessioncorroboration instruction constitutes plain error. We disagree.

It is undisputed that Appellant neither requested a confessioncorroboration instruction nor objected to the jury instructions as 

given at trial and that, thus, appellate review of this claim is limited 

to plain error only. See OCGA § 17-8-58 (b). To establish plain error, 

[the appellant] must demonstrate that the instructional 

error was not affirmatively waived, was obvious beyond

reasonable dispute, likely affected the outcome of the 

proceedings, and seriously affected the fairness, integrity, 

or public reputation of judicial proceedings. Satisfying all 

four prongs of this standard is difficult, as it should be.

Clarke v. State, 308 Ga. 630, 637 (5) (842 SE2d 863) (2020) (citation 

and punctuation omitted). “The Court need not analyze all elements 

of the plain-error test when the appellant fails to establish one of 

them.” Hill v. State, 310 Ga. 180, 194 (12) (a) (850 SE2d 110) (2020). 

Here, Appellant has failed to establish that the omission of the 

confession-corroboration instruction likely affected the outcome of 

the proceedings. Appellant confessed to Wray’s murder not only to 
27

the many Creekstone witnesses but also to Lanier, and he made an 

admission to Brooks by referring to killing Brooks’ “boy.” See 

Sheffield v. State, 281 Ga. 33, 34 (1) (635 SE2d 776) (2006) 

(distinguishing confessions, where entire criminal act is admitted, 

from admissions, where less than all the “facts entering into the 

criminal act” are admitted). In addition, as noted above, various 

facets of Appellant’s confessions were corroborated by other 

evidence; there was a clear motive for Appellant to commit the 

murder; and the ballistics evidence was highly suggestive of 

Appellant’s involvement in Wray’s murder. Because Appellant 

made multiple confessions to different witnesses, which 

corroborated each other, and there was ample evidence 

corroborating the confessions, we conclude that it is unlikely that 

the absence of the confession-corroboration instruction affected the 

outcome of Appellant’s trial. See Clarke, 308 Ga. at 637 (5) (no plain 

error in trial court’s failure to give confession-corroboration 

instruction, where there was ample corroborative evidence); English 

v. State, 300 Ga. 471, 474-475 (2) (796 SE2d 258) (2017) (same).
28

3. Appellant next contends that the Court should evaluate

cumulative prejudice, in accordance with State v. Lane, 308 Ga. 10 

(838 SE2d 808) (2020), to examine the combined prejudicial effect of 

the “errors” alleged in the above two enumerations. See id. at 17 (1) 

(holding that appellate courts must “consider collectively the 

prejudicial effect, if any, of trial court errors, along with the 

prejudice caused by any deficient performance of counsel” – at least 

where those errors and deficiencies involve evidentiary issues). 

Specifically, Appellant contends that the cumulative effect of the 

State’s suppression of evidence regarding Riden’s state and federal 

criminal proceedings and the trial court’s error in failing to give the 

confession-corroboration instruction was sufficiently prejudicial to 

entitle him to a new trial. We disagree.

While the cumulative prejudice rule as announced in Lane has 

so far been applied only to evidentiary error, we have noted the 

possibility of extending cumulative prejudice to other types of 

defects in trial proceedings. See Lane, 308 Ga. at 17-18 (1)

(suggesting that such a possibility could be considered in a future 
29

case). We have also noted the potential difficulty in applying 

cumulative prejudice where the various defects are subject to 

different standards of appellate review. See Finney v. State, __ Ga. 

__ (3) (a) (855 SE2d 578, 589) (2021). Here, the materiality standard 

for a Brady violation (reasonable probability of a different outcome 

at trial) is similar to the plain error standard of review (error likely 

affected the outcome). See Lane, 308 Ga. at 21 (4) n.12 (noting that 

standard for plain error review equates to prejudice standard for 

ineffective assistance); Harris v. State, 309 Ga. 599, 607 (2) (b) (847 

SE2d 563) (2020) (noting that prejudice standard for ineffective 

assistance is rooted in Brady’s materiality standard). Even 

assuming, however, that a Brady violation and an instructional 

error are appropriately assessed as part of a cumulative prejudice 

analysis, we see no cumulative prejudice here. Given the quantum 

and strength of the evidence, independent of Riden’s testimony and 

corroborative of any single confession Appellant made, we conclude 

that it is not reasonably probable or likely that the combination of 
30

the Brady violation and the omitted jury instruction11 affected the 

verdicts against Appellant as to Wray’s murder. See Allen v. State, 

310 Ga. 411, 417-418 (4) (851 SE2d 541) (2020) (no cumulative 

prejudice given strong evidence of defendant’s guilt).

4. Appellant contends that the trial court committed plain 

error by failing to give a jury instruction on the defense of delusional 

compulsion. Claiming that his only plausible defense as to the 

shootings of Officers Howard and Christian was a delusional 

compulsion insanity defense, Appellant contends that the trial court 

was required to instruct the jury on this defense despite the fact that 

he did not request such an instruction. We disagree, because there 

was not even slight evidence to support such an instruction. 

To establish an insanity defense based on delusional 

compulsion, a defendant must show that

at the time of the act, omission, or negligence constituting 

the crime, the [defendant], because of mental disease, 

injury, or congenital deficiency, acted as he did because of 

 11 While we did not expressly conclude that the State violated its duties 

under Brady nor that there was clear error in the trial court’s omission of the 

confession-corroboration instruction, we assume the existence of both defects 

for purposes of this analysis.
31

a delusional compulsion as to such act which 

overmastered his will to resist committing the crime.

OCGA § 16-3-3. In addition, we have held that this defense is 

available only if Appellant “was compelled by [his] delusion to act in 

a manner that would have been lawful and right if the facts had been

as he imagined them to be.” Choisnet v. State, 295 Ga. 568, 571 (2) 

(761 SE2d 322) (2014) (punctuation and citation omitted).

Here, Appellant’s claim of entitlement to a delusional 

compulsion instruction stems solely from his testimony that he shot 

Officers Howard and Christian in response to hearing the voice of 

his deceased brother urging him not to let the officers “do you like 

they done me.” But Appellant has failed to offer any evidence – or 

any claim, for that matter – that at the time of the crimes he suffered

from any “mental disease, injury, or congenital deficiency” as 

required by OCGA § 16-3-3. Moreover, Appellant himself 

acknowledges that, even if his alleged delusion caused him to believe 

he was acting in self-defense, his conduct in shooting the officers 

would not have been “lawful and right” because he was at the time 
32

fleeing to avoid capture for the kidnapping of Brooks. See OCGA § 

16-3-21 (b) (2) (“A person is not justified in using force [in selfdefense] if he . . . [is] fleeing after the commission or attempted 

commission of a felony[.]”). Accordingly, Appellant has failed to 

establish any error, much less any plain error, in the trial court’s 

failure to give a delusional compulsion insanity instruction.

5. Finally, Appellant contends that the trial court erred by 

admitting testimony from a GBI agent about images of Officer 

Christian’s family that were visible on the screen of the on-board 

laptop computer in Officer Christian’s patrol car. During the State’s 

case, GBI Special Agent Jeff Roesler testified about responding to 

the scene of Officer Christian’s murder and was questioned at length 

about the numerous photographs he took during his crime scene 

investigation. Among these photographs were those depicting 

Officer Christian’s patrol car, some of which showed the monitor of 

an on-board laptop computer docked near the car’s center console. 

Agent Roesler testified that during his inspection he noticed the 

laptop screensaver scrolling through various images, and, when 
33

asked specifically whether any of those images showed Officer 

Christian’s family, he responded affirmatively. Though Appellant 

objected to this testimony on grounds of relevance and prejudice, the 

State argued that the photographs showed “what was going on in 

[Officer Christian’s] car at the time he was shot” and thus were 

relevant to disproving justification by showing that the car was not 

in motion at the time of the shooting. The trial court overruled 

Appellant’s objections and allowed the testimony. Upon further 

questioning, Agent Roesler testified about “a photograph of a child 

by himself, and then another child, and . . . a family photograph, and 

. . . other photos coming across as well.”

Pretermitting whether this testimony was properly admitted, 

any possible error in the admission of this testimony was harmless 

in light of the overwhelming evidence of Appellant’s guilt as to the 

murder of Officer Christian. Appellant admits that he intentionally 

shot Officer Christian and, while expressing remorse, he has offered 

neither argument nor evidence that this shooting was justified. 

Thus, it is highly probable that any error in admitting the testimony 
34

in question “did not contribute to the verdict.” Peoples v. State, 295 

Ga. 44, 55 (4) (c) (757 SE2d 646) (2014) (citation omitted) (reciting 

standard for nonconstitutional harmless error). See also Puckett v. 

State, 303 Ga. 719, 721 (2) (814 SE2d 726) (2018) (any error in 

admission of photograph was harmless because evidence of 

appellant’s guilt was overwhelming). In addition, similar testimony 

about these images of Officer Christian’s family was given by 

another law enforcement officer, with no objection by Appellant. 

Thus, to the extent Agent Roesler’s testimony was improperly 

admitted, it was cumulative of other unobjected-to testimony and 

any error in its admission was therefore harmless. See Rutledge v. 

State, 298 Ga. 37, 40 (2) (779 SE2d 275) (2015) (because challenged 

testimony was cumulative of properly admitted evidence, any error 

in admitting it was harmless). 

Judgment affirmed. All the Justices concur.