Mansfield v. State
CourtSupreme Court of Georgia
Date FiledJune 16, 2026
DocketS26A1122
StatusPublished
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Full Opinion
NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court
Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the
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official text of the opinion.
In the
Supreme Court of Georgia
No. S26A1122
Jonathan Mansfield
v.
The State
On Appeal from the Superior Court of DeKalb County
No. 19CR18528
Decided: August 13, 2026
MCMILLIAN, Justice.
Jonathan Mansfield appeals from his convictions for malice
murder and other crimes in connection with the death of Lee Cas-
tillo. 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
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 with-
out 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 pur-
poses. 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).
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 con-
fusing; and (4) the cumulative effect of the errors requires rever-
sal. 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. Mi-
chael 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, Hud-
son 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 miss-
ing.
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 rec-
ords to identify the approximate location of Mansfield at different
times during these events. Agent Berni testified that Mansfield’s
2
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 miss-
ing, 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 Cas-
tillo’s house on February 1 to retrieve some of his personal belong-
ings that he had left there. After arriving around 5:00 p.m., he
waited in the garage until Castillo arrived. When Mansfield ap-
proached Castillo, Mansfield claimed that Castillo was “immedi-
ately like verbally violent” and cursing at him. As Mansfield went
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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 contin-
ued 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 Cas-
tillo’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 ve-
hicle, and had a friend pick him up.
Soon after, Mansfield was arrested and on February 5, In-
vestigator Michele Johnson took pictures of Mansfield. Investiga-
tor Johnson testified that while Mansfield had several cuts and
scratches on his hands, there were no other injuries noted or doc-
umented. 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 ad-
mitting his custodial statement under Miranda and OCGA § 24-
8-824 after he referenced counsel and asked to wait for his lawyer.
This claim fails.
4
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, De-
tective 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 morn-
ing? Do you recall having a conversation with him
about that?
A: I believe he did mention something about a law-
yer. 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
3 See Jackson v. Denno, 378 US 368 (1964).
5
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 volun-
tarily waived them, and that “he thereafter gave a statement
freely and voluntarily without any hope of benefit or fear of in-
jury.” 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-ex-
amination at trial.
When reviewing the admissibility of an in-custody state-
ment, “[t]he trial court’s factual findings and credibility determi-
nations 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 equiv-
alent 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, de-
spite 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
6
(though not actually compelled) can be used to impeach a defend-
ant’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 un-
der the statute is a “promise[] related to reduced criminal punish-
ment – 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 men-
tal 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 exten-
sive 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 ad-
mitted in error on appeal). To show plain error, Mansfield must
show that the trial court made an error that
7
(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 estab-
lish 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 judi-
cial proceedings.”
Id. at 500–01.
Mansfield is not arguing that any individual piece of evi-
dence 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 ar-
gue 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. How-
ever, Mansfield has not cited, nor are we aware of, any authority
requiring a court to do that kind of sua sponte pruning of the ev-
idence. 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 meaning-
ful argument about why specific exhibits should not have been
admitted, Mansfield has not carried his burden of showing error,
8
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 ev-
idence he argued should not have been excluded).
3. Mansfield argues that the voluntary manslaughter in-
structions 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 pro-
voked and acted out of passion.
And I believe this is – this should say voluntary mur-
der 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 de-
cide whether the defendant was sufficiently pro-
voked or acted out in passion, that should say volun-
tary manslaughter. This charge is not correct in the
9
reading of it. …
I’m going to try this again. In considering the
charges of murder and felony murder, you must de-
cide whether the defendant was sufficiently pro-
voked 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 ver-
dict 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 manslaugh-
ter, the State must prove that the defendant caused
the death of another person under circumstances
that would otherwise be murder, and acted only be-
cause of a sudden, violent, and irresistible passion
that resulted from serious provocation which was
sufficient to excite such passion in a reasonable per-
son. If you decide that enough time passed between
the provocation and the killing for a reasonable per-
son 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.
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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 er-
ror, and ultimately gave the proper requested charge to the jury.
See Shorter v. State, 270 Ga. 280, 280 (1998) (any error in charg-
ing the jury was harmless where after “the trial court mistakenly
referred to simple assault as aggravated assault,” the court im-
mediately 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 in-
struction amply cured the error and negated any reasonable prob-
ability that the erroneous statement of law prejudiced the defend-
ant.”).
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 cumula-
tively. See Gines v. State, 324 Ga. 46, 60 (2026) (“[B]ecause [ap-
pellant] has not shown error in any respect, there are not multiple
errors to consider cumulatively, and this claim fails.”).
Judgment affirmed. All the Justices concur, except Warren,
P.J., not participating.
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