The State has made this argument before. See Burlison v. State , 353 Ga. App. 341, 344, 836 S.E.2d 736 (2019) (pretermitting whether Renner ’s holding still applied in light of the new Evidence Code because the flight instruction was harmless). We have explained many times that we look to federal case law for guidance when a provision of Georgia's current Evidence Code mirrors a federal rule of evidence.

After reviewing the entire record, including the evidence of guilt against Wright recounted above (and discussed in Division 2 infra ) on the issue of force, we conclude that the evidence was overwhelming such that any erroneous instruction was harmless. See Huckabee v. State , 287 Ga. 728, 734 (6) (b), 699 S.E.2d 531 (2010) (erroneous jury charge was harmless in light of the overwhelming evidence of the defendant's guilt); Burlison v. State , 353 Ga. App. 341, 344, 836 S.E.2d 736 (2019) (same); see also Haynes v. State , 326 Ga. App. 336, 338 (1), 756 S.E.2d 599 (2014) ("[T]he quantum of evidence to prove force against a child is minimal. And such force may be proven by direct or circumstantial evidence.")

See Flight, Georgia Suggested Pattern Jury Instructions - Criminal § 1.36.10. This very point was at issue recently but left undecided in Burlison v. State , 353 Ga. App. 341, 344, 836 S.E.2d 736 (2019). Because Bully has failed to show an obvious error, he cannot show plain error.