Boykins v. State
294 Ga. 277
| Ga. | 2013Background
- In June 2008 Quinton Denley was shot outside his home and died; the same night a separate shooting victim, Faron Daniels, survived and identified co-indictee Donald Hatton as his shooter.
- Police chased a black Ford Escape; occupants, including Boykins, Hatton, and Preston Whiting, fled. Officers recovered a .380 Lorcin pistol near the Escape and Boykins’ cell phone inside the vehicle.
- Ballistics matched the Lorcin to casings at the Daniels scene and to the casing and projectile from the Denley homicide; marijuana and cash links suggested a drug-related motive.
- Boykins made post-arrest statements admitting ownership of the gun and presence at Denley’s shooting but denied being the shooter; he claimed Whiting shot Denley during a marijuana purchase.
- At trial Boykins presented an alibi via a former girlfriend and photos with timestamped metadata; he was convicted on multiple counts, sentenced to life for malice murder (with felony murder counts vacated), and appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to support convictions | State: Ballistics, possession of gun and cell-phone link, eyewitness and circumstantial evidence support convictions | Boykins: Argued he was not the shooter and advanced an alibi/alternate-perpetrator theory | Affirmed — evidence was sufficient to convict as principal or accomplice under Jackson v. Virginia standard |
| Ineffective assistance of counsel for pursuing alibi instead of mental‑health defense | Boykins: Counsel unreasonably relied on an alibi; should have pursued a mental‑health/insanity defense | State: Trial counsel reasonably investigated mental health, strategically chose an alibi (which would be inconsistent with an insanity defense), and used permitted mental‑health evidence to undermine inculpatory statements | Affirmed — counsel’s choice was a reasonable strategic decision and did not meet Strickland deficient-performance or prejudice standards |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence review)
- Strickland v. Washington, 466 U.S. 668 (two‑prong test for ineffective assistance of counsel)
- Wesley v. State, 286 Ga. 355 (Georgia application of Strickland principles)
- Jackson v. State, 281 Ga. 705 (trial strategy/tactics ordinarily do not establish ineffective assistance)
- Green v. State, 291 Ga. 579 (failure to satisfy either Strickland prong obviates need to analyze the other)