CourtListener 10846000

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NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court
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official text of the opinion.

In the Supreme Court of Georgia

Decided: March 3, 2026

S25A1088. WOODS v. THE STATE.

ELLINGTON, Justice.

Maleik Woods appeals his convictions for malice murder and

possession of a firearm during the commission of a felony in

connection with the shooting death of Francisco Dwayne Zapata.1

Woods asserts as his first claim of error on appeal that the trial court

1 Zapata was shot and killed on November 5, 2018, and on January 15,

2019, a DeKalb County grand jury indicted Woods in connection with the
shooting on charges of malice murder (Count 1); felony murder based on armed
robbery (Count 2); felony murder based on aggravated assault (Count 3);
armed robbery (Count 4); aggravated assault (Count 5); and possession of a
firearm during the commission of a felony (Count 6). Following a jury trial in
November 2019, the jury acquitted Woods on Counts 2 and 4, but found him
guilty on the remaining counts. The trial court sentenced Woods to life in
prison with the possibility of parole on Count 1 and five years to serve on Count
6, to run consecutively to Count 1. The remaining counts were either vacated
or merged. Woods filed a timely motion for new trial, which was twice amended
by new counsel, on January 4, 2021, and November 11, 2024. The trial court
denied the motion on December 23, 2024, and Woods filed a timely notice of
appeal. The case was docketed to the August 2025 term of this Court and
submitted for a decision on the briefs.
abused its discretion in admitting, over objection, evidence of other

acts pursuant to OCGA § 24-4-404(b). Woods also argues that the

trial court committed plain error when it “coerced the deadlocked

jurors into reaching a unanimous verdict.” And Woods contends that

the combined effect of these two errors requires that his convictions

and sentences be reversed. Seeing no merit to these arguments, we

affirm.

Zapata 2 and Woods were friends , and on November 5, 2018,

the two were seen together several times at their mutual friend

Isaac Summage’s house in Gwinnett County. Summage testified

that Woods was unemployed at the time and had been sleeping on

Summage’s couch the previous three nights. Zapata’s girlfriend saw

them there at around 11:30 a.m. when they were sitting in Zapata’s

burgundy Kia in Summage’s driveway. The girlfriend noticed that

Woods, who was sitting in the front passenger seat, was wearing

2 Although the trial transcript identifies the victim in this case as
“Francisco Simpata,” the indictment, the trial court’s order on the motion for
new trial, and other record documents identify the victim as “Francisco
Zapata,” and we refer to him accordingly.
2
black pants and a yellow hoodie. While the two were at Summage’s

house that morning, Summage saw Zapata counting $1,500 in cash

in Woods’s presence. Zapata did not have a bank account and was

known for carrying cash in his wallet. Zapata and Woods left

Summage’s house around noon in Zapata’s Kia and returned around

4:00 or 5:00 p.m. They stayed for around one-half hour and left again

but returned “for a brief moment” after Summage called Zapata and

arranged “to get some weed.”3 Zapata and Woods then left

Summage’s house together in Zapata’s Kia about 7:00 p.m.

Sometime between 7:30 and 7:35 p.m. that evening, as Shakita

White turned into the DeKalb County apartment complex where she

lived, she noticed a burgundy Kia backed into a parking space, with

two people inside. White testified that the person in the driver’s seat

looked like a white female, and the evidence at trial showed that

Zapata had lighter-colored skin and “long hair, a little bit below his

shoulder,” which he always “wore back in like a messy bun.” White

3 The evidence showed that in late 2018, Zapata, who was employed full-

time, was earning extra money by selling marijuana.
3
said the person in the passenger seat was wearing a yellow hoodie.

That same evening, Steven Holland, another apartment

complex resident, was sitting in his car in the complex parking lot,

listening to music, when he “heard a pop” that “sounded like a

gunshot.” Holland went inside his apartment for a time and then

returned to his car and drove toward the complex’s exit. As Holland

was driving toward the exit, he saw a car backed into a parking

space with the driver’s door open and what appeared to be a bag of

clothes on the ground. However, when he drove by the car, Holland

looked closer and saw that there was a body beside the car, with the

legs still in the vehicle and the rest of the body on the ground.

Holland then called 911, parked, and waited for police to arrive. The

evidence showed that Holland’s 911 call was placed at 7:58 p.m. on

November 5, 2018, which Holland said was “[p]robably about 15

minutes” after he heard the “pop.”

Sheila Nesbit, another resident of the complex, testified that

she was inside her apartment when she heard a “loud noise” outside,

followed about 30 seconds later by the same noise again. Nesbit went

4
outside on her deck to see where the noise was coming from, and

about ten minutes later, she saw police lights coming into the

complex. She then observed a police officer go to a car that was

backed into a parking space. Nesbit said that about ten minutes

before she heard the loud noise, she happened to look out her

window and noticed that car in the parking lot. It stood out to her

because it was not a car that usually parked there.

When the first police officer arrived on the scene, at 8:04 p.m.,

Holland was waiting in his vehicle and directed the officer to a

burgundy Kia. The officer approached the vehicle and observed a

person lying on the ground, with one leg still in the vehicle through

the open driver’s side door. The officer first reported that the victim

was female, but upon closer inspection he realized the victim was

male. The officer determined that the man had been shot, but the

body was still warm, and the officer thought he detected a light

pulse. He began performing chest compressions until emergency

medical help arrived and moved the victim. When the lead detective

arrived sometime later, emergency medical personnel were on the

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scene and had determined that the man, later identified as Zapata,

was dead.

Investigators later determined that the apartment complex

was about a 26-minute to one-hour drive from Summage’s house,

depending on traffic. A subsequent analysis of cell phone records

from Woods’s phone showed that on the night of the shooting it was

utilizing a cell tower located within approximately two miles of the

apartment complex between 7:38 and 7:41 p.m. Officers also

retrieved a photo from Woods’s cell phone showing Woods in a yellow

hoodie. A video retrieved from Summage’s cell phone also showed

Woods wearing a yellow hoodie.

Summage testified that Woods called him on Facetime around

1:00 a.m. the morning after the shooting, and the first words out of

Woods’s mouth were “I had to do it to him.” Summage testified that

he understood that Woods was referring to Zapata. And when

Summage, also referring to Zapata, asked, “bro died, bro is dead?”

Woods became “like frantic” and said, “bro, I swear to God, I didn’t

kill him.” Then Woods told Summage he would call him back and

6
disconnected the call, but Woods never called Summage back or

returned to Summage’s house.

An autopsy revealed that Zapata died of a gunshot wound to

the back consistent with a shot fired from a handgun. From a search

of Zapata’s Kia, investigators determined that the car was likely the

main crime scene. Zapata’s cell phone was inside the car, and officers

found a single shell casing on the driver’s side floorboard. Based on

the location of the casing, investigators believed that it came from a

semi-automatic handgun fired from inside the car. Investigators

also discovered a wallet in the car, but no cash was found in the car

or on Zapata’s person. Zapata’s Kia was impounded for further

investigation. When the police later released the car to Zapata’s

stepfather, he turned on the car’s engine and searched the

dashboard display for the last phone connected to the car. The screen

read: “Retro searching,” and the evidence showed that Zapata and

others referred to Woods by the nickname “Retro.”

Vontaria Carlton testified at trial about an earlier incident

involving Woods (hereinafter referred to as “the May 21 incident”).

7
Carlton said that on May 21, 2018, she visited Lakaylah Walker at

Walker’s house. Walker and Woods had a child together, and Woods

was at the house when Carlton arrived. As Carlton entered the

house, Woods and Walker were arguing. When Woods started “to go

towards” Walker, Walker told Woods to leave and that the police had

been called. Walker’s baby was in another room crying, and Carlton

picked up the baby to try to calm her. At that point, Carlton also told

Woods to leave, and he began cursing at Carlton. Woods then pulled

out a gun and pointed it at Carlton while she was holding the baby.

Carlton said that Woods eventually put the gun away and started

physically fighting with Walker, pulling her hair, choking her, and

hitting her before the police arrived.

1. Woods argues that evidence from the May 21 incident was

improperly admitted for purposes of knowledge and intent pursuant

to OCGA § 24-4-404(b) (“Rule 404(b)”) and that he was harmed by

the admission of the improper evidence. 4

4 Woods’s enumeration of error on this issue includes language
suggesting that he also is asserting a claim of ineffective assistance of trial

8
“We review a trial court’s evidentiary rulings under an abuse

of discretion standard of review.” Williams v. State, 302 Ga. 474, 478

(2017) (quotation marks omitted). “And even where an abuse of

discretion is shown, there are no grounds for reversal if the error did

not affect a ‘substantial right,’ and thus harm, the defendant.”

Venturino v. State, 306 Ga. 391, 393 (2019); OCGA § 24-1-103(a)

(“Error shall not be predicated upon a ruling which admits or

excludes evidence unless a substantial right of the party is

affected[.]”). Where, as in this case, the alleged error is non-

counsel based on counsel’s failure to object to the prosecution’s closing
argument concerning this evidence. In addition, Woods asserts in his brief that
the issue of ineffective assistance of counsel was preserved for appeal because
it was raised at the first available opportunity. However, Woods does not
otherwise address the issue of ineffective assistance of counsel in his appellate
briefing. He asserts no specific argument regarding that issue, nor does he cite
any legal authority addressing the issue’s merits. We conclude, therefore, that
to the extent that Woods attempts to assert a claim of ineffective assistance of
counsel on appeal, he has failed to carry his burden to establish such a claim.
See Clark v. State, 321 Ga. 732, 737 (2025) (“To prevail on a claim of ineffective
assistance, an appellant bears the burden of showing both that trial counsel’s
performance was professionally deficient and that he was prejudiced as a
result of that deficient performance.” (citing Strickland v. Washington, 466
U.S. 668, 695 (1984)); Clark v. State, 307 Ga. 537, 543–44 (2019) (rejecting an
ineffective-assistance-of-counsel claim where the appellant argued that
comments were inadmissible but made “no argument, much less a sufficient
showing, that the trial court erred in concluding that trial counsel’s decision
not to object was [not] objectively unreasonable”).
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constitutional, “we examine whether it is highly probable that the

error did not contribute to the verdict by reviewing the record de

novo and weighing the evidence as we would expect reasonable

jurors to have done.” Pounds v. State, 320 Ga. 288, 294 (2024)

(cleaned up).

Rule 404(b) provides that “[e]vidence of other crimes, wrongs,

or acts shall not be admissible to prove the character of a person in

order to show action in conformity therewith.” OCGA § 24-4-404(b).

Such evidence, however, may be admissible for other purposes, such

as “proof of motive, opportunity, intent, preparation, plan,

knowledge, identity, or absence of mistake or accident,” if the

evidence is relevant for proving that other purpose. Id. Where a trial

court errs in admitting Rule 404(b) evidence, we generally have

found such errors harmless “where the properly admitted evidence

was so strong that the prejudicial effect of the other-acts evidence

had no significant influence on the guilty verdicts.” Dickerson v.

State, ___ Ga. ___ (2026), S25A1365, slip op. at 11-12 (Ga. Jan. 21,

2026) (2026 WL 151134) (quotation marks omitted). See also

10
Nundra v. State, 316 Ga. 1, 6 (2023).

Additionally, this Court previously has stated that jury

instructions limiting the use of 404(b) evidence can reduce the effect

that such evidence might have on a jury’s decision, where the

evidence of guilt is strong. See, e.g., Priester v. State, 316 Ga. 133,

138–39 (2023) (concluding that any error in the admission of

evidence that the appellant committed an armed robbery and shot

at a car during a drug deal on the day before he committed the

charged crimes was harmless, given that the trial court instructed

the jury that it could not infer propensity from that evidence and

that the other evidence of his guilt was strong); Nundra, 316 Ga. at

8 (determining that the trial court’s “admonition that the jury may

not infer from [the 404(b)] evidence that the accused is of a character

that would commit such crimes reduce[d] the likelihood that the

evidence of [the defendant’s] past crimes influenced the verdict”

(quotation marks omitted)); Williams v. State, 313 Ga. 443, 450

(2022) (“Because we ordinarily presume that jurors follow [the trial

court’s instructions], any unfair prejudice from the admission of the

11
[Rule 404(b)] evidence was reduced.” (quotation marks omitted)).

Here, the State filed a pre-trial request to introduce evidence

of the May 21 incident pursuant to Rule 404(b). At a later hearing

on the issue, the State proffered the evidence for the purpose of

showing intent and knowledge. The prosecutor explained that the

State’s theory of the case was that Woods shot Zapata while robbing

him at gunpoint, noting that Woods had no job, he knew Zapata was

carrying cash after seeing Zapata with $1,500 that day, and no

money was found at the crime scene. The prosecutor argued that the

State needed the evidence of the May 21 incident because

investigators had not found the gun used in the shooting and the

State wanted to show that just months earlier, Woods had pointed a

gun at someone else he knew intimately. The next day, the trial

court entered an order admitting the evidence for the purposes of

knowledge and intent.

Before Carlton testified at trial, the trial court gave a limiting

instruction on the use of the evidence regarding the May 21 incident

and repeated that instruction in its general charge to the jury. Those

12
instructions directed the jurors to consider the Rule 404(b) evidence

“only insofar as it may relate” to the issues of knowledge and intent

that the State must prove in the crimes charged in the case on trial

and that they “may not infer from such evidence that the defendant

is of a character that would commit such crimes.”

Even assuming, without deciding, that the trial court abused

its discretion in admitting the evidence of the May 21 incident, we

conclude that any such error was harmless. The State presented

strong circumstantial evidence to support Woods’s convictions. The

evidence showed that Woods and Zapata spent much of November

5, 2018, together and that they left Summage’s house together in

Zapata’s burgundy Kia around 7:00 p.m. White saw two people

matching Zapata’s and Woods’s descriptions sitting in Zapata’s

burgundy Kia in the complex parking lot at around 7:30 to 7:35 p.m.

The person whom White described as a white female fit Zapata’s

description, and the clothing worn by the person in the passenger

seat matched that worn by Woods earlier that day. The dashboard

display in Zapata’s car indicated that Woods’s cell phone appeared

13
to have been the last phone connected to the car’s communication

system, and Woods’s cell phone data showed that Woods’s cell phone

was in the area of the complex between 7:38 and 7:41 p.m. Witness

testimony placed the sound of a gunshot just minutes later, as

Holland said he heard the shot approximately 15 minutes before he

made the 911 call at 7:58 p.m., which would place the shot at around

7:43 p.m.

Additionally, evidence collected at the scene supported that the

shot that killed Zapata was fired from inside the Kia, and Zapata’s

body was found shot in the back and hanging out of the driver’s side

door. Although Zapata had $1,500 earlier in the day and his wallet

was found in the car, no cash was discovered at the crime scene.

Hours after the shooting, Woods placed a video call to Summage in

which Woods said that he “had to do it to him.” Summage understood

“him” to refer to Zapata, and Woods appeared “frantic” when

Summage asked if Zapata were dead.

Moreover, the State did not mention the May 21 incident in

opening statement and made, at most, only two brief references to

14
the evidence in closing, and we have stated that under such

circumstances, the prejudicial effect of Rule 404(b) evidence may be

minimized. See Redding v. State, 320 Ga. 107, 118 (2024). And the

trial court twice instructed the jury that the evidence of the May 21

incident was being introduced for the limited purposes of knowledge

and intent, and in each set of instructions, the court specifically

directed the jurors that they could not use the evidence to determine

that Woods had the character to commit the acts charged against

him.

Accordingly, because the State presented strong, properly

admitted evidence of Woods’s guilt and the trial court provided

limiting instructions on the use of the Rule 404(b) evidence, we

conclude that it is highly probable that any error in admitting the

evidence of the May 21 incident did not contribute to the jury’s guilty

verdicts. See Dickerson, slip op. at 13–14. See also Nundra, 316 Ga.

at 8. Woods’s claim of error on this ground fails.

2. Woods also contends that the trial court committed plain

error “when it coerced the deadlocked jurors into reaching a

15
unanimous verdict.”

Because Woods did not raise a timely objection to the trial

court’s instructions that he now asserts were “coercive,” we review

his claim only for plain error. See Hill v. State, 310 Ga. 180, 194 n.8

(2020); OCGA § 17-8-58(b). To prevail on plain-error review, an

appellant must show that the trial court’s alleged instructional error

“was not affirmatively waived; was clear and obvious, rather than

subject to reasonable dispute; likely affected the outcome of the trial;

and seriously affected the fairness, integrity, or public reputation of

judicial proceedings.” Clark v. State, 315 Ga. 423, 440 (2023)

(quotation marks omitted). “If one prong of the plain error test is not

satisfied, we need not address the other prongs of the test.” Baker v.

State, 319 Ga. 456, 462 (2024). Moreover, “[s]atisfying this high

standard is difficult, as it should be.” Id. (quotation marks omitted).

The jury in this case began deliberating on Thursday,

November 7, 2019, at 1:57 p.m. Sometime later that afternoon, the

jury sent a note asking to see two pieces of evidence. The jury was

brought back into the courtroom where the trial court responded to

16
the jury’s request, and the jurors resumed their deliberations at 4:29

p.m. Later, when the trial judge sent the deputy to ask the jurors

when they wanted to break for the evening, the jury replied with a

note that read, “We’re not able to come to a unanimous decision.”

The trial court brought the jury back into the courtroom, and,

without directly responding to the note, released the jurors for the

day at around 6:02 p.m. Woods’s counsel raised no objection to this

procedure.

Jury deliberations resumed the next morning, Friday

November 8, at 8:57 a.m., and sometime before noon, the jury sent

out another note asking, “What happens if a unanimous decision

cannot be reached?” The trial judge stated that it was too early for

an Allen5 charge. Counsel for both sides concurred and agreed with

the trial court’s suggestion to send the jury a message to “keep

deliberating.” Accordingly, Woods’s counsel agreed with this

procedure. Later that afternoon, the jury sent the trial judge another

5 Allen v. United States, 164 US 492 (1896).

17
note that read, “We are at an impasse, and it is being stated that no

amount of deliberation will change the opinions.” The trial judge told

counsel that he intended to bring the jurors into the courtroom to

tell them that they would be deliberating until 5:00 p.m., and if no

verdict was reached, they would return Tuesday morning, after a

long holiday weekend, to resume deliberations.

At this point, Woods’s counsel moved for a mistrial “since this

is the third time that [the jurors] have said something of this

nature.” The trial court summarily denied the motion but stated

that he would give the jury an Allen charge on Tuesday if it did not

reach a verdict. The trial court called the jurors back into the

courtroom and told them:

So, I know you've been deliberating for quite a while now.
But we’re going to—I’m just going to give you the
schedule. We’re going to probably go today until about
five, and then we will be coming back on Tuesday—
Tuesday morning at nine if you do not reach a decision
today by five. Okay? So, I’m just giving you the schedule.
And then we’ll be back on our normal schedule for the rest
of next week, with lunch at twelve and going to about five.
Okay? All right. You’re excused.

Woods’s counsel did not object to these instructions, and the jury

18
then resumed its deliberations around 3:16 p.m. with the plan to

cease deliberations around 5:00 p.m. No verdict was reached on

Friday.

When the trial resumed on Tuesday, November 12, the jury

continued its deliberations and reached a verdict later that day, in

which the jurors found Woods guilty of malice murder, felony

murder based on aggravated assault, aggravated assault, and

possession of a firearm during the commission of a felony but

acquitted him of the charges of felony murder based on armed

robbery and armed robbery. The trial court conducted a poll of the

jury, asking each juror, “Is this your verdict?” and “Is this still your

verdict?” The jurors individually responded in the affirmative to

both questions.

In denying Woods’s motion for new trial on this ground, the

trial court determined that the jury deliberated approximately 16

hours over three business days, which the court found was “not

remarkable” in a murder case based on circumstantial evidence. It

also concluded that the jury was not impermissibly coerced.

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Woods asserts, however, that the trial court erred in directing

the jurors to keep deliberating in spite of their notes indicating that

they had not reached a unanimous decision and asking what would

happen if they did not do so. He also asserts that the trial court’s

announcement of the schedule for deliberations for the following

week of trial signaled to the jurors that a hung jury was not

acceptable and that they were required to deliberate indefinitely

until they reached a unanimous verdict.

The determination of whether a jury is hopelessly deadlocked

is a sensitive one best made by the trial court that has observed the

trial and the jury, Bannister v. State, 306 Ga. 289, 296 (2019)

(quotation marks omitted), and a trial court’s determination in that

regard is subject to reversal only for an abuse of discretion. Smith v.

State, 302 Ga. 717, 718 (2017) (quotation marks omitted). Moreover,

the determination of “[w]hether a verdict was reached as the result

of coercion depends upon the totality of the circumstances.” Id.

(quotation marks omitted). And this Court has considered the

following in determining whether the trial court’s decision to require

20
further deliberations amounted to coercion:

the length of trial, the length of deliberations before the
jury indicates that it is deadlocked, the language of the
jury’s notes, the progress of the jury, the language of the
Allen charge and other instructions regarding
deliberations, the length of additional deliberations after
the alleged coercion, whether the jury found the
defendant not guilty of any charges, and the polling of the
jury.

Smith, 302 Ga. at 721.

In addition, trial judges are vested with broad discretion with

respect to administrative or trial management instructions, and

such discretion “will not be controlled by this court unless it is

manifestly abused.” Edwards-Tuggle v. State, 320 Ga. 558, 562–63

(2024) (quotation marks omitted). “The judge’s discretion in

controlling the conduct of a trial necessarily includes the power to

determine the length of time the jury will be allowed to deliberate

on a given day.” Id. See also OCGA § 15-1-3 (4) (“Every court has

power ... [t]o control, in the furtherance of justice, the conduct of its

officers and all other persons connected with a judicial proceeding

before it, in every matter appertaining thereto[.]”).

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The trial in this case lasted for over three days, and the jury

deliberated under four hours before sending the first message

indicating that it was unable to reach a unanimous decision. The

next day, deliberations continued for fewer than six hours before the

jury sent its last note indicating that it was at an impasse. But at no

point did the notes indicate that the jury was “hopelessly

deadlocked.” See Bannister, 306 Ga. at 296. At most, the final note

indicated that the jury had reached an “impasse,” and some person

or persons stated that further deliberation “would not change

opinions.” But even if the jurors had indicated that they were

“hopelessly deadlocked,” see id., a trial court is not bound by such a

pronouncement. “On the contrary, the trial court, in the exercise of

a sound discretion, [is] required to make its own determination as to

whether further deliberations were in order.” Sears v. State, 270 Ga.

834, 838 (1999). After the third note, the trial court instructed the

jury as to what the schedule for deliberations would be for the

remainder of the day and into the following week if necessary. The

trial court never gave an Allen charge. And when the jury reached

22
its verdict, it found Woods not guilty on two counts. Each juror

confirmed the verdict when polled by the trial court.

Considering the totality of the circumstances, the trial court’s

instructions to the jurors after receiving their notes were not

impermissibly coercive, and, therefore, it did not abuse its discretion

in giving those instructions. See Porras v. State, 295 Ga. 412, 420

(2014) (determining that the trial court’s instructions were not

“coercive simply because they compelled the jury to continue

deliberating after it reported a deadlock”). And the trial court’s

instructions setting out the schedule for future deliberations cannot

be understood as forcing the jury to reach a unanimous verdict as

Woods contends. “Rather, the court’s statements constituted

administrative guidance for the jury concerning how long they

would likely be deliberating that evening and in the coming days,

guidance that clearly fell within the wide discretion afforded trial

judges in managing their courtrooms.” Edwards-Tuggle, 320 Ga. at

563.

Therefore, Woods failed to establish that the trial court erred,

23
much less that it clearly and obviously erred, in responding to the

jury’s notes, and because Woods failed to establish at least one of the

elements of plain error, his claim fails. See Sellers v. State, ___ Ga.

___ (2026), S25A1044, slip op. at 12 (Ga. Jan. 5, 2026) (2026 WL

20439) (holding claim of plain error in trial court’s jury instruction

fails because Appellant failed to show clear and obvious error in

giving a jury charge).

3. Woods further asserts that if we identify error based on the

arguments above, but find that any such error was harmless, we

should review the cumulative effect of both errors.

“To establish cumulative error[,] [an appellant] must show that

(1) at least two errors were committed in the course of the trial; [and]

(2) considered together along with the entire record, the multiple

errors so infected the jury’s deliberation that they denied [the

appellant] a fundamentally fair trial.” State v. Lane, 308 Ga. 10, 21

(2020) (quotation marks omitted). Here, we assumed error on

Woods’s argument that the trial court abused its discretion in

admitting evidence of the May 21 incident but concluded that such

24
error was harmless. And we identified no error in the trial court’s

instructions to the jury during their deliberations. Accordingly,

because Woods failed to show more than one error at trial, this Court

has no errors to aggregate for purposes of a cumulative error

analysis. Woods’s argument on this ground fails. See Flood v. State,

311 Ga. 800, 808–09 (2021).

Judgment affirmed. All the Justices concur.