Angulo v. State, 314 Ga. App. 669

Angulo was convicted of multiple armed robberies and aggravated assaults stemming from a July 6, 2007 Northcrest Apartments robbery.
Five men were robbed at gunpoint; all victims identified Angulo in photographic lineups and four testified and identified him in court.
The State introduced similar-transaction evidence of a 2004 robbery involving Angulo and accomplices; one victim recognized Angulo but did not testify later.
Angulo testified, admitting a 2005 theft by taking of an automobile but denying involvement in the 2007 crimes, claiming alibi and lack of supportive witnesses.
The jury convicted Angulo of five counts each of armed robbery and aggravated assault; the trial court vacated one armed-robbery conviction and directed acquittal on one aggravated-assault count.
On appeal Angulo challenged (1) failure to record voir dire, (2) admissibility of prior-conviction evidence for impeachment, and (3) ineffective assistance of trial counsel; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Voir dire recording	Angulo claims denied juror-for-cause motions were unrecorded.	State and court ignored recorded objections; error should reverse.	No reversible error; lack of voir dire record not harmful.
Admission of prior conviction for impeachment	Trial court applied a liberal standard permitting impeachment by prior conviction.	Even if standard was mis-stated, evidence was harmless given strong identifications.	Harmless error; overwhelming identifications substantial.
Ineffective assistance—voir dire transcription	Counsel's failure to transcribe voir dire prejudiced Angulo.	No prejudice shown; Strickland standard not met.	No ineffective assistance; no prejudice shown.
Ineffective assistance—alibi questioning	Counsel should have objected to alibi-burden shifting questions.	Such cross-examination allowed inference about missing witnesses; no error.	No ineffective assistance; permissible line of questioning.
Ineffective assistance—similar-transaction evidence	Counsel should have objected to adding 'identity' as a purpose for similar-transaction evidence.	The evidence was properly presented and overwhelming; added wording did not prejudice.	No ineffective assistance; no prejudice from limiting-instruction error.

McConnell v. State, 263 Ga.App. 686, 589 S.E.2d 271 (2003) (voir dire record requirement and harmless-error analysis)
Primas v. State, 231 Ga.App. 861, 501 S.E.2d 28 (1998) (general rule on absence of voir dire record and harm)
Johnson v. State, 307 Ga.App. 791, 706 S.E.2d 150 (2011) (prior-conviction admissibility standard and harmless-error review)
Sims v. State, 281 Ga. 541, 640 S.E.2d 260 (2007) (meritless objections cannot support ineffective-assistance claims)
Moore v. State, 301 Ga.App. 220, 687 S.E.2d 259 (2009) (impact of similar-transaction evidence and limiting instructions)
Morgan v. State, 267 Ga. 203, 476 S.E.2d 747 (1996) (admissibility and inference arguments in trial strategy)