Bryant v. State, 293 Ga. 754

Victim Candiace Person was found dead from asphyxiation/strangulation on Nov. 26, 2005; phone lines at the home had been cut.
Semen recovered from the victim’s vagina produced DNA that the State’s expert said did not exclude Willie Lee Bryant but was not a definitive match.
Bryant had a prior sexual relationship with the victim and admitted to consensual sex but denied murder; he had a prior indictment for a similar assault where he allegedly cut phone lines, entered, choked, and raped a former girlfriend.
Additional circumstantial evidence tied Bryant to the area: his frequenting a nearby hotel and proximity to fraudulent use of the victim’s credit card after the murder.
Bryant was convicted of malice murder, felony murder (vacated by operation of law), rape, aggravated assault, and burglary; sentenced to life plus consecutive years; he appealed claiming ineffective assistance for failure to obtain a DNA expert.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for not calling a DNA expert	Bryant: counsel’s failure to obtain independent DNA testimony was deficient and prejudiced the outcome	State: counsel consulted an independent expert who said testimony would mirror the State’s; counsel cross-examined the State expert to highlight inconclusiveness	Court: No ineffective assistance — counsel acted reasonably and there is no reasonable probability of a different outcome

Jackson v. Virginia, 443 U.S. 307 (jury verdict reviewed for sufficiency of evidence)
Strickland v. Washington, 466 U.S. 668 (two-prong ineffective assistance standard — performance and prejudice)
Fuller v. State, 277 Ga. 505 (appellate review of ineffective assistance requirements)
Robinson v. State, 277 Ga. 75 (deference to trial court factual findings, independent legal review)
Wright v. State, 291 Ga. 869 (discussion of ineffective assistance standards in Georgia)
Malcolm v. State, 263 Ga. 369 (vacatur of felony-murder convictions by operation of law)