Blackmon v. State, 302 Ga. 173

On December 6, 2011, Isaiah Blackmon and co-defendant Dejuan Spratlin arrived at Stanton Gilliam’s home during a marijuana sale; Edward Cobb, a neighbor, also came to the house.
After payment, Blackmon produced a gun, demanded money and property, a struggle ensued, multiple shots were fired; Cobb was shot and later died; Gilliam was shot in the leg and survived.
Ballistics showed .38 and .40 caliber rounds; at least two and possibly three guns were used.
Blackmon and Spratlin were later arrested together; neither testified at trial. Blackmon’s phone received texts referencing sale of guns, and he told his mother he gave a gun to someone to get rid of.
A jury acquitted Blackmon of malice murder but convicted him of felony murder, two counts of aggravated assault (one merged), and possession of a firearm during a crime; sentence: life for felony murder plus consecutive terms.
On appeal Blackmon argued (1) insufficient evidence to support convictions (including rejection of self-defense) and (2) ineffective assistance of trial counsel (failure to consult, failure to file written self-defense request, failure to seek severance).

Issue	Blackmon's Argument	State's Argument	Held
Sufficiency of evidence to support convictions / rejection of self-defense	Evidence insufficient; shooting justified or ambiguous	Evidence supported jury’s rejection of justification; identification, ballistics, flight, statements support convictions	Affirmed — evidence sufficient under Jackson v. Virginia standard
Ineffective assistance — inadequate consultation	Counsel failed to consult adequately pretrial, impairing defense	No specific prejudice shown; no required amount of conference time; no identified reasonable alternative acts	Denied — no deficient performance shown
Ineffective assistance — failure to file written self-defense request	Counsel erred by not filing written request when justification was sole defense	Counsel made an oral request and court instructed jury on self-defense	Denied — meritless because instruction was given
Ineffective assistance — failure to seek severance from co-defendant	Counsel should have moved to sever to avoid harmful co-defendant statements and separate defenses	Counsel made strategic choice to present unified justification defense to limit Bruton implications; trial court likely would have denied severance; no prejudice shown	Denied — strategic decision reasonable; no prejudice demonstrated

Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency-of-evidence standard)
Strickland v. Washington, 466 U.S. 668 (sets two-part ineffective assistance standard)
Bruton v. United States, 391 U.S. 123 (rules on co-defendant statements and confrontation implications)
Anthony v. State, 298 Ga. 827 (jury may reject justification defense)
Vega v. State, 285 Ga. 32 (credibility and conflict resolution for jury)
Arnold v. State, 292 Ga. 268 (prejudice burden in ineffective assistance claims)
Henry v. State, 279 Ga. 615 (no fixed consultation-time requirement for counsel-client communication)
Thomas v. State, 300 Ga. 433 (counsel’s strategic choices on severance and Bruton risks can be reasonable)