Boynton v. State, 317 Ga. App. 446

Defendant Richard Boynton was convicted by a Muscogee County jury of multiple armed robbery, aggravated assault, burglary, and weapons offenses.
Prosecution introduced similar transaction evidence about a November 23, 2008 attempted robbery to prove course of conduct and modus operandi.
The additional incident involved a red convertible, a masked gunman, and a loaded pistol found in the car; details matched the victim’s description.
Defendant’s co-defendants pled guilty; Satterfield and Tinch testified for the State at trial.
The defense challenged the admissibility of the similar transaction evidence and later asserted ineffective assistance of counsel for multiple objections.
The trial court admitted the similar transaction evidence for course of conduct and MO, with limiting instructions; on appeal, the court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of similar transaction evidence	State	Boynton	Admissible for MO and course of conduct
Ineffective assistance regarding admission objections	State	Boynton	No reversible error; objections were reasonable or harmless
Admission of shackles photo	State	Boynton	Proper, not ineffective assistance
Jury charge on similar transaction	State	Boynton	Any error harmless; limiting instruction promptly given

Pareja v. State, 286 Ga. 117 (2009) (three-prong test for admissibility of similar transactions)
Flowers v. State, 269 Ga. App. 443 (2004) (discretion in admitting similar transaction evidence)
Collum v. State, 281 Ga. 719 (2007) (focus on similarities rather than differences)
Beck v. State, 291 Ga. App. 702 (2008) (logical connection required for similar transactions)
Moore v. State, 301 Ga. App. 220 (2009) (slip of the tongue during charge corrected; no reversal)
Knowles v. State, 245 Ga. App. 523 (2000) (arrest-related photographs admissible as evidence)
Mitchell v. State, 242 Ga. App. 177 (2000) (record admissibility principles for closing arguments)