Brown v. State, 293 Ga. 518

On July 19, 2008, Benjamin Brown purchased crack from Ron Williams, later returned, and fatally stabbed Williams; Brown was arrested nearby with two knives (one bloodstained) and gave a post-Miranda statement claiming self-defense.
Brown was indicted for murder, felony murder, aggravated assault, and possession of a knife during a felony; a jury convicted him of felony murder (predicated on aggravated assault), aggravated assault (merged for sentencing), and possession of a knife during a felony.
Brown was sentenced to life for felony murder and an additional five years (suspended) for the knife count; he filed a motion for new trial asserting ineffective assistance of counsel and appealed after denial.
At trial Brown testified the stabbing was in self-defense and that a friend, Antoine Richardson, was with him; Richardson did not testify at trial and was not produced as a corroborating witness.
The trial court found Brown’s trial counsel was experienced, investigated witnesses, received Richardson’s contact information only very late (on the eve of or during trial), attempted to locate him without success, and concluded counsel’s performance was not deficient and that Brown suffered no prejudice.

Issue	Brown's Argument	State's Argument	Held
Whether counsel was ineffective for failing to locate/subpoena Antoine Richardson	Counsel failed to locate Richardson and call him to corroborate Brown’s self-defense claim	Counsel investigated, received Richardson’s info only very late, attempted to find him, and was not deficient; even if deficient, no prejudice given strong evidence	Trial court affirmed: counsel not deficient; alternatively Brown failed to show Strickland prejudice
Whether the evidence was sufficient to support convictions	(implicit) Brown argued factual dispute over self-defense	State: evidence supported guilt beyond reasonable doubt	Court held Jackson sufficiency satisfied; a rational juror could convict

Strickland v. Washington, 466 U.S. 668 (establishes two-prong ineffective-assistance standard: deficient performance and prejudice)
Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence review)
White v. State, 283 Ga. 566 (Georgia application of Strickland)
Johnson v. State, 290 Ga. 382 (appellate review accepts trial-court factual findings but independently applies law)
Freeman v. State, 278 Ga. 349 (counsel not deficient where witness location was essentially unknown)
Harris v. Upton, 292 Ga. 491 (counsel not deficient for failing to locate a witness whose whereabouts are unknown)
Malcolm v. State, 263 Ga. 369 (merger/sentencing principle cited)