Alford v. State, 320 Ga. App. 523

Alford was convicted by a jury of one count of child molestation and two counts of sexual battery involving his girlfriend’s two daughters (E.S. and I.S.).
He challenged the conviction via a motion for new trial alleging ineffective assistance of counsel.
Evidence at trial included testimony from E.S. and I.S., their tenth-grade teacher, a school counselor, and a detective; E.S. and I.S. testified about long-term abuse spanning 2003–2009.
The trial court denied the motion for new trial after an evidentiary hearing; the court of appeal affirmed the conviction.
Alford testified in his defense denying abuse and suggesting the girls fabricated allegations to upset him after family dynamics changed.
The State did not introduce the note from I.S. under the Child Hearsay Statute due to age considerations, and the court addressed objections to bolstering and relevance throughout.]
(Note: The background condenses the core facts and procedural posture relevant to appellate review.)

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of E.S.’s reaction to I.S.’s note	State contends reactions were admissible to explain conduct, not to bolster I.S.	Alford argues the testimony was hearsay/relevancy/bolstering and should have been excluded	Yes; admissible as non-hearsay and relevant to explain conduct under former OCGA § 24-3-2
Effect of the teacher’s unresponsive bolstering remark	State argues remark did not prejudice due to overall credibility and cross-examination of I.S.	Failure to object was ineffective assistance	Prejudice not shown; remark did not affect outcome; no reversible error
Sufficiency of the evidence to support convictions	Evidence showed multiple sexual abuses over years; corroboration and victim testimony supported verdict	Defense contested credibility and timing; no reasonable jury could convict	Evidence sufficient to sustain convictions beyond a reasonable doubt
Ineffective assistance for failing to object to bolstering by teacher	State relies on cumulative testimony and consistency of witness accounts	Counsel’s failure to object was deficient performance	No prejudice; insufficient to show a reasonable probability of different outcome

Momon v. State, 249 Ga. 865 (Ga. 1982) (OCGA § 24-3-2 admissibility for conduct/motive explanations)
Pruitt v. State, 274 Ga. 708 (Ga. 2002) (reasons for delayed reporting relevant to credibility under former § 24-3-2)
Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (establishes standard for ineffective assistance claims)