Thus, we conclude that the cumulative effect of the assumed errors does not entitle Bowman to a new trial. See Jennings v. State, 318 Ga. 579, 592-93 (4), 899 S.E.2d 210 (2024) (combined prejudicial effect of assumed trial court error and deficiencies by counsel did not warrant new trial where evidence against defendant was strong); Lofton v. State, 309 Ga. 349, 366-67 (7), 846 S.E.2d 57 (2020) (combined prejudicial effect of assumed trial court errors and deficiency by counsel did not deprive defendant of his right to a fair trial where properly admitted evidence of defendant’s guilt was strong). Judgment affirmed.
Under these circumstances, even if we assume that some of the prisoner's statements in the text messages were inadmissible under Rule 803 (3), it is highly probable that their admission did not contribute to the verdict. See Pounds v. State, __Ga. __, __(3) (b) (Case No. S24A0884, decided Nov. 5, 2024) (assuming without deciding that admission of statements violated Rule 803 (b), but concluding that any error in their admission was harmless "in light of all of [the] evidence against [the defendant]" presented by the State); Jennings v. State, 318 Ga. 579, 588 (2) (899 S.E.2d 210) (2024) ("Given the other strong evidence at trial, Jennings cannot show that the introduction of the Facebook messages . . . between her and Street likely affected the outcome of the trial court proceedings, particularly since Street testified about the content of the messages."); Williams v. State, 316 Ga. 304, 314 (4) (888 S.E.2d 60) (2023) (concluding that any error in admitting hearsay was harmless in light of the strength of the evidence identifying and inculpating the defendant and because it was cumulative of other testimony).
"In assessing whether evidence is necessary in this context, [our Supreme Court has] noted that ‘necessary’ is not used in a strictly literal sense, but rather, refers to what evidence is reasonably necessary for the [s]tate to complete the story of the crime." Jennings v. State, 318 Ga. 579, 584 (1), 899 S.E.2d 210 (2024) (citation and punctuation omitted). Evidence that advances the state’s theory of the case can be "necessary to complete the story of the crime for the jury…."