Watson v. State

The trial court did not err in denying the defendant's motion for directed verdict of acquittal, because there was evidence showing that the defendant was connected to the crimes of robbery and theft by receiving stolen property arising from a smash-and-grab robbery at a jewelry store in a mall.

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Rodrekus Watson, convicted of robbery as a lesser included offense of armed robbery and theft by receiving stolen property, appeals from the denial of his motion for new trial. He argues that the trial court erred in denying his motion for a directed verdict made after the State’s case-in-chief, and urges us to overrule precedent from the Supreme Court of Georgia providing that we may consider all the trial evidence, not just the evidence introduced during the State’s case-in-chief, in evaluating this claim. Watson also argues that trial counsel was ineffective for failing to object to or request a limiting instruction with regard to references to his status as a convicted felon. Because we have no authority to overrule or modify a decision of the Supreme Court of Georgia, and the evidence did not demand a verdict of acquittal, we reject Watson’s first claim of error. We also conclude that Watson’s claim that counsel was ineffective fails because, given the strong evidence connecting Watson to the robbery, he has failed to establish a reasonable probability that the outcome of his trial would have been different but for his counsel’s error. Therefore, we affirm.

On appeal from the denial of a motion for directed verdict, this Court must view the trial evidence in the light most favorable to the jury’s verdict. Helton v. State, 284 Ga. App. 777, 777-78 1 644 SE2d 896 2007. So viewed, the trial evidence shows that three men participated in a smash-and-grab robbery at a jewelry kiosk in a mall. The assailants used hammers to shatter the glass display cases, took jewelry from the cases, and fled the scene in a stolen car. After the assailants fled, the kiosk employee noticed blood on top of the glass display case that was not there prior to the robbery.

Watson v. State

The trial court did not err in denying the defendant's motion for directed verdict of acquittal, because there was evidence showing that the defendant was connected to the crimes of robbery and theft by receiving stolen property arising from a smash-and-grab robbery at a jewelry store in a mall.

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