Brown v. State, 292 Ga. 454

Garry Brown sustained a fatal head injury and subdural hemorrhage; initial injury likely trauma and occurred within days before hospitalization.
Garry had bruises and a possible bite mark; appellant claimed Garry walked from his bedroom that morning and had not fallen recently.
Appellant suggested a prior sofa fall at her aunt's five days earlier as the cause; hospital staff advised keeping crib side rails up, which Appellant repeatedly lowered.
Garry fell from the crib on August 11, causing a second injury; he died after emergent neurosurgery.
State experts opined Garry’s first injury and second fall were not consistent with the initial incident; a combination of injuries led to death.
Defense presented evidence of the neighbors’ opinions, appellant’s demeanor, and Garry’s pediatrician testimony; defense argued lack of negligence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence sufficient to support murder conviction?	Brown contends insufficient evidence for malice murder.	State argues evidence proved guilt beyond reasonable doubt.	Yes; evidence legally sufficient to support verdict.
Was trial counsel's strategy ineffective in not calling a defense expert?	Counsel should have presented a defense expert on initial injury.	Counsel's cross-examination strategy was reasonable and not deficient.	No; strategy deemed reasonable, not ineffective.

Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (standard for sufficiency review)
Hubbard v. State, 285 Ga. 791 (Ga. 2009) (trial strategy in handling expert testimony)
Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (ineffective assistance framework)
Long v. State, 287 Ga. 886 (Ga. 2010) (standard for ineffective assistance analysis)
Phillips v. State, 285 Ga. 213 (Ga. 2009) (precedent on expert testimony and defense strategy)