MANSFIELD v. STATE (2026)

Jonathan Mansfield appeals from his convictions for malice murder and other crimes in connection with the death of Lee Castillo.¹ On appeal, Mansfield argues that (1) the trial court erred in admitting Mansfield's custodial statement in violation of his rights under Miranda ² and OCGA § 24-8-824; (2) the admission of extensive crime-scene and autopsy photographs and other physical evidence created unfair prejudice such that a new trial is required; (3) the voluntary manslaughter instruction was confusing; and (4) the cumulative effect of the errors requires reversal. For the reasons that follow, we affirm.

The record shows that at 6:28 p.m. on February 1, 2019, Castillo called 911 to report that someone he knew was breaking into his house, although Castillo did not identify the person. Michael Hudson, one of Castillo's neighbors, testified that the same night, he heard “screaming for a while,” including hearing “please, no, stop.” After walking in front of Castillo's house, Hudson saw a silhouette of “somebody, like, raising – all I could see was somebody raising their arm, essentially, and bringing it down.” He stated that when he called out to ask if everything was okay, there was no response but “you could tell that he turned and then looked ․ he definitely looked like he had been caught doing something.” When responding officers arrived at the scene, they found a large amount of blood around the carport of the house and Castillo, who was deceased. The crime technician noted that there was a strong odor of gas in the house and saw a gas can next to the carport door, as well as some burn and charred patterns on the hardwood floor. Inside the house on a table was a brick stained with blood. Also, Castillo's 2017 Toyota Corolla was missing.

The next morning, a patrol officer found Castillo's car in Chattanooga. DNA tested from blood on the steering wheel and from cigarette butts found in the car both matched Mansfield's DNA. At trial, FBI special agent James Berni testified to using Mansfield's cell phone records and mapping based on those records to identify the approximate location of Mansfield at different times during these events. Agent Berni testified that Mansfield's phone was in the general area of the murder during the time of the murder based on his phone using the closest phone tower to the crime scene at 7:27 p.m. Also, Mansfield's phone was located in Chattanooga, using phone towers near where Castillo's car was eventually found at 11:20 p.m. the night of the incident.

Castillo's partner Will Smith testified that he lived with Castillo and that they considered themselves to be married. Smith testified that he and Castillo met Mansfield through video games, and that after a few months, Mansfield began visiting them and would visit once a month for a few days at a time. About a week before the incident, they discovered that Mansfield tried to use their credit card without their approval. They tried to call Mansfield about the card use multiple times but never heard back from him. Mansfield was no longer welcome in their home at that point. After leaving for work the afternoon of February 1, Smith came back to the house around midnight to find police at their house and on their street. When he finally was able to get into the house, he discovered that several video game consoles were missing, as well as an Apple watch. The next morning, while cleaning the back porch, Smith found a gold necklace outside on the back patio near where Castillo's body was found, which Smith believed belonged to Mansfield.

Mansfield testified in his own defense that he met Castillo through online gaming around October of 2017. A few months later, he began meeting Castillo and Smith in person, ultimately about 12 times in total. Mansfield claimed that he went to Castillo's house on February 1 to retrieve some of his personal belongings that he had left there. After arriving around 5:00 p.m., he waited in the garage until Castillo arrived. When Mansfield approached Castillo, Mansfield claimed that Castillo was “immediately like verbally violent” and cursing at him. As Mansfield went to get his items from the house by going around Castillo, Castillo pulled a gun from his hip. Mansfield reached for the gun, and they “got into a wrestling match slash fight over the gun.” After the gun “went flying,” Castillo grabbed a brick and hit Mansfield with it. Mansfield then grabbed his knife out of his pocket and began stabbing Castillo because he was “scared that this guy was going to kill me if I didn't do something.” Mansfield and Castillo continued fighting over the knife until Mansfield grabbed a brick and hit Castillo in the head, ending the fight. Mansfield testified that he then tried to call 911, but the call did not go through. He went to collect his things in the house, called his friend, grabbed Castillo's car keys, and since he was “freaking out,” grabbed a nearby gas can and started pouring gas around the home and on clothes that he had taken off Castillo and lit the gas on fire before leaving. He then drove to Chattanooga in Castillo's car, abandoned the vehicle, and had a friend pick him up.

Soon after, Mansfield was arrested and on February 5, Investigator Michele Johnson took pictures of Mansfield. Investigator Johnson testified that while Mansfield had several cuts and scratches on his hands, there were no other injuries noted or documented. The medical examiner who conducted Castillo's autopsy stated that there were multiple blunt force trauma injuries to Castillo's face and head, along with some sharp object injuries. He concluded that the cause of death was “the sharp blunt force injuries of the head, neck, torso, and extremities” and that the manner of death was homicide.

1. Mansfield first argues that the trial court erred in admitting his custodial statement under Miranda and OCGA § 24-8-824 after he referenced counsel and asked to wait for his lawyer. This claim fails.

During trial, the trial court held a Jackson-Denno ³ hearing on whether statements Mansfield made during an interview with Detective Scott Demeester were admissible. At the hearing, Detective Demeester testified that he interviewed Mansfield in Chattanooga. After reading Mansfield his rights under Miranda, Mansfield indicated that he understood his rights. Detective Demeester stated that he did not threaten Mansfield, nor did he make him any promises to answer any questions. Subsequently, Detective Demeester testified to the following:

Q: And you asked Mr. Mansfield, do you understand what all those rights I just read to you, right? And he said my lawyer is supposed to be here this morning? Do you recall having a conversation with him about that?

A: I believe he did mention something about a lawyer. But he reinitiated the conversation so that he wished to speak with me without a lawyer.

Q: And in part, he said, can't you just wait until my lawyer gets here. Like, I've been here, I got to get back to Atlanta?

A: I don't remember that. ․

Q: He basically said, can you wait till my lawyer gets here and, like, you know what. He said you don't want to talk to me. I'm going to head back to Atlanta. We might be able then. Something along those lines?

A: Not – not quite. If I remember correctly, I told him that I – I would not be coming back up, and that he would be extradited to Georgia at some point. He would be given a lawyer or he can purchase a lawyer if you can't afford one.

Q: And ultimately, he said he wanted to talk to you?

A: Correct.

The trial court found that Mansfield was advised of his rights under Miranda, that he understood his rights and voluntarily waived them, and that “he thereafter gave a statement freely and voluntarily without any hope of benefit or fear of injury.” The recording of the interview was not admitted at the Jackson-Denno hearing or at trial, although certain statements from the interview were used to impeach Mansfield on cross-examination at trial.

When reviewing the admissibility of an in-custody statement, “[t]he trial court's factual findings and credibility determinations regarding the admissibility of in-custody statements will be upheld on appeal unless clearly erroneous.” Szorcsik v. State, 303 Ga. 737, 739 (2018). “The clearly erroneous standard is equivalent to the highly deferential ‘any evidence’ standard, which means we will not reverse a trial court's factual findings if there is any evidence in the record to support them.” Morrell v. State, 313 Ga. 247, 251 (2022).

First, Mansfield's claim fails under Miranda because, despite his argument on appeal, his statement to the police was never admitted into evidence and was used only to impeach him when he testified at trial, which is a permissible purpose even for an un-Mirandized statement. See United States v. Patane, 542 US 630, 639 (2004) (“[S]tatements taken without Miranda warnings (though not actually compelled) can be used to impeach a defendant's testimony at trial.”).

Mansfield also argues that the interview was conducted in violation of OCGA § 24-8-824, which provides that no confession by a defendant is admissible unless it was “made voluntarily, without being induced by another by the slightest hope of benefit or remotest fear of injury.” Mansfield suggests that his statement was not voluntary under OCGA § 24-8-824 because the detective pressured him to give a statement in Chattanooga, rather than waiting until he was extradited back to Georgia where he might have counsel appointed. But that is not the kind of pressure that renders a confession inadmissible under OCGA § 24-8-824. The kind of “hope of benefit” that makes a confession inadmissible under the statute is a “promise[ ] related to reduced criminal punishment – a shorter sentence, lesser charges, or no charges at all,” see Mitchell v. State, 314 Ga. 566, 573–74 (2022), and the type of “fear of injury” contemplated by the statute is “[p]hysical or mental torture,” id. at 573. Mansfield points to no evidence of anything of that nature. To the contrary, Detective Demeester testified that he did not make any threats or promises, and the trial court was authorized to credit that testimony․

2. Mansfield argues that the admission and use of extensive crime-scene, autopsy, and physical exhibits created unfair prejudice and caused harm, requiring a new trial.

Because Mansfield did not object to any of the evidence that he now claims should not have been admitted, this enumeration is reviewed for plain error only. See Dees v. State, 322 Ga. 498, 500 (2025) (noting that “our review is for plain error only” where appellant failed to object at trial to the evidence claimed to be admitted in error on appeal). To show plain error, Mansfield must show that the trial court made an error that

(1) was not affirmatively waived, (2) was “clear and obvious,” which generally means there must be “on-point controlling authority” or “the unequivocally clear words of a statute or rule” that “plainly establish that the trial court erred,” (3) likely affected the outcome of the trial, and (4) “seriously affected the fairness, integrity, or public reputation of the judicial proceedings.”

Id. at 500–01.

Mansfield is not arguing that any individual piece of evidence was not relevant or admissible, but rather that “in a case turning on malice, justification, and mitigation, the cumulative volume and emotional force of this proof required closer Rule 403 balancing or limiting guidance to prevent the jury from using graphic and repetitive evidence as a substitute for proof of the contested mental-state issues.” That is, Mansfield appears to argue that the trial court, in the absence of any objection to the crime-scene, autopsy, and physical evidence, should have sua sponte given a limiting instruction or weighed the probative value against the danger of unfair prejudice and excluded some of the evidence as unnecessarily cumulative and inflammatory. However, Mansfield has not cited, nor are we aware of, any authority requiring a court to do that kind of sua sponte pruning of the evidence. Therefore, he has not established a clear or obvious error. See Simmons v. State, 299 Ga. 370, 374 (2016) (“[A]n error is plain if it is clear or obvious under current law. An error cannot be plain where there is no controlling authority on point.”) (cleaned up).

Moreover, by failing to identify the specific evidence that should have been excluded under Rule 403 or to provide meaningful argument about why specific exhibits should not have been admitted, Mansfield has not carried his burden of showing error, much less plain error. See Henderson v. State, 304 Ga. 733, 739 (2018) (holding that the appellant was not entitled to a review of his claims where he did not “specifically identify the objectionable testimony ․ and d[id] not include any meaningful legal analysis,” but rather “simply makes vague assertions or error and cites to chunks of the transcript”); McGarity v. State, 311 Ga. 158, 163 (2021) (holding that the appellant “has demonstrated no error – plain or otherwise,” where he failed to specifically identify the evidence he argued should not have been excluded).

3. Mansfield argues that the voluntary manslaughter instructions were confusing and created a substantial risk that the jury confused felony murder and voluntary manslaughter.

After Mansfield requested a voluntary manslaughter charge, to which the State objected, the trial court ultimately agreed to give the charge. However, while giving the charge, the trial court identified an error. Specifically, the trial court charged as follows:

In considering the felony murder charge, you must decide whether the defendant was sufficiently provoked and acted out of passion.

And I believe this is – this should say voluntary murder charge instead of felony murder. As I said, I will give you this corrected copy. I'm sorry. We went back and forth on this one. If you find this, you may not return a verdict of guilty – okay. Let me make sure I get this right.

In considering felony murder charge, you must decide whether the defendant was sufficiently provoked or acted out in passion, that should say voluntary manslaughter. This charge is not correct in the reading of it. ․

I'm going to try this again. In considering the charges of murder and felony murder, you must decide whether the defendant was sufficiently provoked and acted out of passion. If you find this, you may not return a verdict of guilty of murder or felony murder, but you would be authorized to return a verdict of guilty of voluntary manslaughter.

The State must prove beyond a reasonable doubt that the offense should not be reduced from murder to voluntary manslaughter. Voluntary manslaughter, the State must prove that the defendant caused the death of another person under circumstances that would otherwise be murder, and acted only because of a sudden, violent, and irresistible passion that resulted from serious provocation which was sufficient to excite such passion in a reasonable person. If you decide that enough time passed between the provocation and the killing for a reasonable person to have cooled off and regain judgment, then the killing is not voluntary manslaughter.

At a later point during the jury charge, the trial court again noted that the corrected voluntary manslaughter charge would be provided to the jury, stating that “I am going to have my staff attorney make the correction on the voluntary manslaughter charge that I completely botched, and I thank you all for helping me figure out to make sure that that wording is correct. So we will make sure that that wording is correct in the charge that they receive.” The voluntary manslaughter charge ultimately given by the trial court was the language requested by Mansfield.

Because Mansfield did not object to this charge at trial, this enumeration is also reviewed for plain error. See Simmons v. State, 291 Ga. 705, 712 (2012) (“When a party fails to object to a jury charge or the omission of a charge during trial but raises the issue on appeal, this Court reviews the charge for plain error.”). Pretermitting whether Mansfield affirmatively waived this claim, any error made by the trial court in giving the charge likely did not affect the outcome of the trial. As recounted above, the trial court corrected its mistake, alerted the jury that there was an error, and ultimately gave the proper requested charge to the jury. See Shorter v. State, 270 Ga. 280, 280 (1998) (any error in charging the jury was harmless where after “the trial court mistakenly referred to simple assault as aggravated assault,” the court immediately gave the correct charge and that “the trial court's slip of tongue did not mislead or confuse the jury.”); Sims v. State, 266 Ga. 417, 418–19 (1996) (any error in accomplice corroboration charge was harmless where the trial court's “timely curative instruction amply cured the error and negated any reasonable probability that the erroneous statement of law prejudiced the defendant.”).

4. Finally, Mansfield argues that the cumulative effect of the errors requires reversal. However, this enumeration fails as Mansfield has not shown multiple errors to consider cumulatively. See Gines v. State, 324 Ga. 46, 60 (2026) (“[B]ecause [appellant] has not shown error in any respect, there are not multiple errors to consider cumulatively, and this claim fails.”).

Judgment affirmed.

FOOTNOTES

1.   The crimes were committed on February 1, 2019. In April 2019, a DeKalb County grand jury indicted Mansfield for malice murder (Count 1), three counts of felony murder (Counts 2-4), two counts of aggravated assault (Counts 5 and 6), and burglary in the first degree (Count 7). At a jury trial in February 2024, Mansfield was found guilty of all counts except Count 4. On March 7, 2024, the trial court sentenced Mansfield to serve life in prison without the possibility of parole for malice murder (Count 1) and a consecutive term of twenty years in prison for burglary in the first degree (Count 7). The other counts were either vacated by operation of law or merged for sentencing purposes. Mansfield timely filed a motion for new trial, which was amended through new counsel on October 19, 2025. Following a hearing, the trial court denied the motion for new trial, as amended, on December 10, 2025. Mansfield timely filed a notice of appeal, and his case was docketed to this Court's April 2026 term and submitted for a decision on the briefs.

2.   See Miranda v. Arizona, 384 US 436 (1966).

3.   See Jackson v. Denno, 378 US 368 (1964).

McMillian, Justice.

All the Justices concur, except Warren, P.J., not participating.