Bulloch v. State, 293 Ga. 179

Bulloch was convicted of malice murder and felony murder for the beating death of Paul McKeen, Jr., with trial conducted alongside co-defendants.
Evidence shows Bulloch admitted to drug dealing, debt disputes with McKeen, and threats prior to the beating; Bulloch and co-defendants allegedly beat McKeen and transported him to a remote location.
McKeen was found unconscious with blunt-force head injuries one morning after the events, later dying; cause of death was blunt-force trauma.
Bulloch told a police watcher that he and others severely beat McKeen over the debt; a prior beating of another man by Bulloch and Reagan was also noted.
The State introduced out-of-court statements from McKeen’s wife and brother; the defense challenged hearsay and validity under hearsay exceptions.
Bulloch pursued a motion for new trial arguing ineffective assistance of counsel, which the trial court denied; this appeal follows.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of hearsay statements	Bulloch argues wife/brother statements were inadmissible hearsay.	Bulloch asserts necessity and reliability justify admission under former OCGA § 24-3-1 (b).	Husband’s statement admitted under necessity; brother’s statement conceded waivable error; no reversal.
Ineffective assistance of counsel	Bulloch claims counsel’s failures prejudiced trial outcome across multiple grounds.	Bulloch asserts counsel’s performance was deficient and prejudicial under Strickland.	No deficient performance; strategy reasonable; not ineffective under Strickland.
Crossexamination and alibi evidence	Bulloch argues counsel failed to present adequate alibi or impeach witnesses.	Counsel’s decisions, including waiving some alibi evidence when Bulloch testified, were strategic.	Trial strategy justified; no ineffective assistance shown.
Venue instruction	The court gave a faulty conspiracy-based venue instruction and misstatement of venue law.	Any error was harmless when viewed in context of the entire charge and evidence.	Harmless error; venue instructed properly overall; no reversible verdict effect.
Sufficiency of evidence	Evidence supported a rational jury’s guilty verdict beyond a reasonable doubt.	Defects in trial might undermine guilt beyond reasonable doubt theory.	Evidence sufficient; rational jury could convict.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for guilt beyond reasonable doubt)
Waits v. State, 282 Ga. 1 (Ga. 2007) (state ineffective assistance framework; standards applied)
Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (testimonial statements require confrontation rights)
Teague v. State, 252 Ga. 534 (Ga. 1984) (limitations on hearsay and reliability determinations)
Watson v. State, 278 Ga. 763 (Ga. 2004) (particularized guarantees of trustworthiness in necessity exception)
Momon v. State, 249 Ga. 865 (Ga. 1982) (hearsay exceptions and declarant reliability considerations)
Adams v. State, 288 Ga. 695 (Ga. 2011) (confrontation and hearsay considerations in specific context)