Bradshaw v. State, 300 Ga. 1

In March 2008, Earl Gill was beaten and later died of blunt-force head injuries after Roy Lee Bradshaw and co-defendants (the Morrises) forcibly detained and assaulted him; blood and a bloody bat were found in Bradshaw’s van.
Bradshaw gave two custodial statements to police the same day; after a Miranda advisal he initially denied involvement, then later confessed in a second interview.
Bradshaw, his wife Teresa (who later pled guilty to voluntary manslaughter and testified for the State), and the Morrises were jointly tried; a jury convicted Bradshaw of malice murder, aggravated assault, and robbery; life without parole plus consecutive terms were imposed.
At a Jackson-Denno hearing the trial court found Bradshaw’s statements were voluntarily given; the court credited officers’ testimony that Miranda warnings were given verbally and that no coercion or promises occurred.
On appeal Bradshaw claimed (1) his custodial statements were involuntary and Miranda warnings inadequate, and (2) trial counsel rendered ineffective assistance by not moving to sever and by failing to investigate/challenge voluntariness.
The Supreme Court of Georgia affirmed: it deferred to trial-court credibility findings, rejected the voluntariness claim, and held counsel’s strategic decisions were not deficient under Strickland.

Issue	Bradshaw's Argument	State's Argument	Held
Admissibility/voluntariness of custodial statements (Miranda)	Statements inadmissible: not properly Mirandized, not freely given, coerced/physically assaulted	Officers provided verbal Miranda warnings; statements voluntary under totality of circumstances	Court affirmed trial findings: warnings were given verbally, waiver was voluntary, statements admissible
Preservation of coercion/assault claim	Police physically assaulted/coerced him and threatened his wife, nullifying voluntariness	These allegations first raised in motion for new trial and thus not preserved for appellate review; trial record shows no coercion	Court held coercion claims not preserved; voluntariness otherwise unsupported
Ineffective assistance — failure to move to sever	Counsel should have sought severance due to antagonistic defenses and prejudice from joint trial	Counsel investigated severance, reasonably concluded motion would fail; defendant failed to show actual prejudice or meet severance test	Court held counsel not deficient; no prejudice shown, claim fails under Strickland
Ineffective assistance — failure to investigate custodial coercion	Counsel failed to investigate alleged assault, lack of written waiver, and missing recording	Counsel raised Miranda/waiver issues at Jackson-Denno hearing; client never told counsel about assault/threats; counsel’s investigative choices reasonable	Court found counsel’s performance not deficient; Strickland prongs not met

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
Miranda v. Arizona, 384 U.S. 436 (warning requirement for custodial interrogation)
Jackson v. Denno, 378 U.S. 368 (procedures for determining voluntariness of confessions)
Strickland v. Washington, 466 U.S. 668 (two-prong ineffective-assistance-of-counsel test)
Harrington v. Richter, 562 U.S. 86 (deference to reasonable strategic decisions by counsel)
Vergara v. State, 283 Ga. 175 (trial-court admissibility determination: preponderance standard)
Clay v. State, 290 Ga. 822 (de novo review of legal application to facts after deferential factual review)