Blackmon v. State, 302 Ga. 173

On December 6, 2011, Isaiah Blackmon and co-defendant Dejuan Spratlin went to purchase a pound of marijuana from Stanton Gilliam at Gilliam’s home; a neighbor, Edward Cobb, joined them.
After Appellant gave $1,025 for the marijuana, Appellant produced a gun, demanded valuables, shot Gilliam (wounding him) and Cobb (who later died). Spratlin and Appellant left with the money and marijuana.
Ballistics and shell casings at the scene showed both .38 and .40 caliber rounds; a firearms expert concluded at least two, possibly three guns were used.
Appellant and Spratlin were later found together and arrested; Appellant’s phone received texts about selling guns, and he told his mother he “gave the gun to someone to get rid of.” Neither defendant testified; the jury was instructed on self-defense but rejected it.
A DeKalb County grand jury indicted both men for malice murder, felony murder, two counts of aggravated assault, and possession of a firearm during a crime. At the joint trial, Blackmon was acquitted of malice murder but convicted of felony murder, aggravated assault, and the firearm count; sentenced to life plus consecutive terms.
On appeal Blackmon argued (1) insufficient evidence to support convictions and (2) ineffective assistance of trial counsel; the Georgia Supreme Court affirmed.

Issue	Blackmon's Argument	State's Argument	Held
Sufficiency of the evidence for convictions (including felony murder)	Evidence did not prove guilt beyond a reasonable doubt; claimed self-defense	Evidence (witness ID, ballistics, cash transfer, flight, phone texts, statements) supports convictions and jury rejection of self-defense	Affirmed: evidence sufficient when viewed in light most favorable to verdict (Jackson standard)
Ineffective assistance — inadequate consultation with counsel	Trial counsel failed to consult adequately before trial, harming defense	No specific prejudice shown; no required minimum conference time; appellant failed to identify how extra consultation would help	Affirmed: no deficient performance shown (Strickland)
Ineffective assistance — failure to file written request for self-defense instruction	Counsel should have filed written request for the instruction (sole defense)	Court gave a self-defense instruction after an oral request; no prejudice	Affirmed: meritless because jury received instruction
Ineffective assistance — failure to move for severance from co-defendant	Counsel failed to seek severance; joint trial harmed Blackmon	Defense strategy was to present a unified justification defense and limit admission of co-defendant statements; trial court indicated it would likely deny severance; no reasonable probability of a better outcome at separate trials	Affirmed: strategic choice was reasonable; no prejudice shown (Bruton strategy considered)

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
Strickland v. Washington, 466 U.S. 668 (two-part test for ineffective assistance: performance and prejudice)
Bruton v. United States, 391 U.S. 123 (limitations on admission of co-defendant statements at joint trials)
Anthony v. State, 298 Ga. 827 (jury may reject justification defense)
Vega v. State, 285 Ga. 32 (credibility and conflict resolution are jury functions)
Thomas v. State, 300 Ga. 433 (strategic decisions about severance and Bruton issues may be reasonable)
Henry v. State, 279 Ga. 615 (no fixed minimum time for attorney-client conferences)
Arnold v. State, 292 Ga. 268 (emphasizing heavy burden to show Strickland prejudice)