Bostic v. the State, 341 Ga. App. 402

Travis Bostic was tried for malice murder, felony murder, three counts of aggravated assault, and possession of a firearm by a convicted felon after a nightclub shooting that left one person dead and another injured.
The jury convicted Bostic of two counts of voluntary manslaughter (as lesser-included offenses), three counts of aggravated assault, and possession of a firearm by a convicted felon.
Bostic filed a motion for new trial raising ineffective-assistance-of-counsel claims, alleging counsel failed to preserve and present a self-defense affirmative defense, and complaining that a victim photograph displayed on a monitor and on shirts in the courtroom prejudiced the jury.
The trial court held a hearing on the motion for new trial, denied relief, and found counsel’s strategy consistent with Bostic’s pretrial preferences and testimony at the hearing.
On appeal, Bostic argued ineffective assistance, courtroom publicity of a victim photograph, and that jury selection producing an all-white jury was unconstitutional; he provided little to no citation or argument for several claims.
The Court of Appeals affirmed, deeming several issues abandoned for lack of argument/citation and finding no deficient performance or prejudice regarding the asserted failure to preserve self-defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for failing to preserve/present self-defense	Bostic: counsel failed to file required notice and thus prevented assertion of self-defense	State: Bostic did assert self-defense at trial; counsel’s tactical choices were reasonable and aligned with defendant’s wishes	Denied — counsel not ineffective; self-defense presented and charged; no prejudice shown
Whether counsel committed other errors in asserting self-defense (unspecified)	Bostic: counsel made a series of errors and failed to object to prosecutor’s comment on silence	State: arguments unsupported and undeveloped	Abandoned for appeal due to lack of record citation/authority
Whether a victim photograph on a monitor and shirts prejudiced the jury	Bostic: display improperly influenced jury	State: contested but Bostic provided no supporting argument or authority	Abandoned for appeal due to lack of record citation/authority
Whether an all-white jury resulted from unconstitutional selection (venire)	Bostic: jury selection unconstitutional	State: issue not developed in appellate brief	Abandoned/insufficiently argued — court affirmed judgment

Fuller v. State, 320 Ga. App. 620 (evidence reviewed in light most favorable to verdict)
Scott v. State, 290 Ga. 883 (ineffective-assistance two-prong standard)
Johnson v. State, 287 Ga. 767 (trial-court factual findings on counsel effectiveness reviewed for clear error)
Murray v. State, 295 Ga. 289 (jury may disbelieve a self-defense claim)
Grier v. State, 273 Ga. 363 (strategic choices generally not ineffective assistance)
Thrasher v. State, 289 Ga. App. 399 (appellate briefs without authority can be treated as inadequate)
Paul v. State, 266 Ga. App. 126 (self-defense is an affirmative defense)
Matthews v. State, 285 Ga. App. 859 (alibi is not an affirmative defense)
Patterson v. State, 327 Ga. App. 695 (issues unsupported by argument/citation may be deemed abandoned)