Benton v. State, 300 Ga. 202

Shortly after midnight on Sept. 3, 2009, Jasmine Lynn was fatally shot and Jarvis Jones was wounded during a melee near Clark Atlanta University; six 9mm casings were found on Mitchell Street.
Benton was seen earlier that night wearing a red hooded shirt, reddish Mohawk, and carrying a distinctive tan-and-red "Gucci" book bag; his fingerprints were later found on the bag and an item inside it, and he admitted the bag was his and that he left it at the scene.
Witnesses testified the shooter ran down Mitchell Street (where shots were fired) carrying a book bag; Brandon Hall identified Benton at trial as the shooter; Benton admitted lying to police and changing his hair after the shooting.
Benton testified he was present but that his friend Clarence Carter (who wore dreadlocks) fired the shots; Benton and others had previously coordinated a false account to investigators.
Jury convicted Benton of felony murder (life), aggravated assault (concurrent 25 years), and possession of a firearm during a felony (consecutive 5 years); malice murder charge was acquitted and gang charge nolle prosequi.
Post-trial, Benton raised (1) a public-trial claim based on limited courthouse access on a Saturday and (2) ineffective assistance of counsel for failing to interview/call witness Darius Brooks; both claims were rejected and judgments affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Courthouse closure / public-trial right	Benton: denying family access to Saturday proceedings infringed his Sixth/Fourteenth rights	State/Court: procedures announced; Benton failed to object at trial	Waived for appeal; no relief (no contemporaneous objection)
Ineffective assistance — failure to interview/call Brooks	Benton: counsel's failure was deficient and prejudiced outcome by undermining ID evidence	State: counsel's actions were reasonable; Brooks's testimony would not have created reasonable probability of different outcome	Denied — failed Strickland prejudice prong
Sufficiency of evidence	Benton did not contest on appeal	N/A	Court independently reviewed and found evidence sufficient under Jackson v. Virginia
Identification reliability	Benton: witness Brooks would have shown Hall couldn't ID shooter initially and others misidentified hair; would impeach Hall/Hall's ID	State: Brooks's statements did not contradict that the shooter ran down Mitchell with a book bag; multiple witnesses linked book bag and shooter to Benton	Court: Brooks's testimony would not have reasonably changed the verdict; physical evidence (fingerprints on bag) and multiple eyewitnesses supported ID

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence review)
Peretz v. United States, 501 U.S. 923 (failure to timely assert a constitutional right can forfeit it)
Spickler v. State, 276 Ga. 164 (contemporaneous objection required to preserve trial error)
Reid v. State, 286 Ga. 484 (public-trial claim must be objected to at trial)
Henderson v. State, 207 Ga. 206 (public access and trial procedures)
State v. Abernathy, 289 Ga. 603 (unchallenged courtroom closure claims may be raised only via ineffective assistance claim)
Smith v. Francis, 253 Ga. 782 (Strickland framework applied in Georgia)
Strickland v. Washington, 466 U.S. 668 (ineffective assistance — performance and prejudice prongs)
Redding v. State, 297 Ga. 845 (deference to counsel tactical decisions unless patently unreasonable)
Robinson v. State, 277 Ga. 75 (appellate review accepts trial court factual findings; legal conclusions reviewed de novo)
Sanders v. State, 290 Ga. 637 (no Strickland prejudice where new witness would not likely change outcome)
Allen v. State, 286 Ga. 392 (same)