Arnold v. State
292 Ga. 268
Ga.2013Background
- Arnold was tried by an Athens-Clarke County jury and convicted of malice murder (reduced by law to life), aggravated stalking, and aggravated assault, with felony murder vacated by operation of law.
- He challenged the conviction claiming his trial counsel gave ineffective assistance by not adequately investigating his mental health.
- Evidence showed Arnold and his estranged wife Lakeisha separated in August 1999; Lakeisha obtained a protective order barring contact.
- On December 15, 1999, Arnold shot Mattox and Lakeisha, killing Mattox with a close-range headshot; he surrendered after admitting the shooting.
- Trial proceeded with a voluntary manslaughter instruction as a lesser included offense; Arnold argued counsel failed to obtain a mental health evaluation that could have changed trial strategy.
- At issue on appeal was whether trial counsel’s decision to pursue a different mental-health-based defense and her failure to obtain a formal psychological evaluation amounted to ineffective assistance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance for mental health investigation | Arnold argues counsel failed to adequately investigate mental health and obtain evaluation | Arnold's counsel conducted reasonable investigation and relied on available records | No reversible error; performance was reasonable under Strickland standard |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes deficient performance and prejudice test for ineffective assistance)
- Kimmelman v. Morrison, 477 U.S. 365 (U.S. 1986) (clarifies analysis applies to pre-trial investigations)
- McKiernan v. State, 288 Ga. 140 (Ga. 2010) (counsel not ineffective where some investigation occurred and strategic decision made)
- Martin v. Barrett, 279 Ga. 593 (Ga. 2005) (counsel's failure to obtain mental-health evidence can be non-deficient where records reviewed)
- Whitus v. State, 287 Ga. 801 (Ga. 2010) (prejudice shown where additional examination would affect trial outcome)
- Futch v. State, 286 Ga. 378 (Ga. 2010) (reasonableness judged as of time of trial, not hindsight)
- Shank v. State, 290 Ga. 844 (Ga. 2012) (delays in post-conviction proceedings can affect rights but not outcome of appeal)