Castillo-Velasquez v. State, 305 Ga. 644

On June 16, 2013, at a public soccer-game championship, Saul Castillo-Velasquez shot and killed Silverio Acosta; multiple eyewitnesses placed Castillo-Velasquez at the scene and reported he said "I shot him, he killed my father."
Castillo-Velasquez claimed he acted under delusional compulsion and in self-defense, testifying to childhood trauma, schizophrenia, hallucinations, and cessation of medication months before the shooting.
The State introduced prior-other-act evidence: a 2004 New York incident where Castillo-Velasquez fired at three men; the State admitted this under OCGA § 24-4-404(b) to prove intent.
Castillo-Velasquez was convicted of malice murder and possession of a firearm in the commission of a crime; he appealed challenging (1) admission of the New York act, (2) admission of the victim’s bloody clothes, and (3) trial counsel’s failure to introduce portions of his New York medical records.
The trial court had instructed the jury on self-defense and delusional compulsion; the jury rejected the insanity/delusion defense and found intent.

Issue	Castillo-Velasquez's Argument	State's Argument	Held
Admissibility of New York other-act under OCGA § 24-4-404(b)	Evidence was more prejudicial than probative and too remote	Other-act was admissible to rebut delusional-compulsion defense because intent was at issue; prosecutorial need and similarities supported admission	Admission was not an abuse of discretion; probative value outweighed prejudice
Rule 403 exclusion of victim’s bloody clothes	Bloody clothes were unduly prejudicial and should have been excluded	Clothes were relevant and probative; any prejudice was harmless given other graphic evidence	No plain error shown; even if error, not harmful given strength of evidence
Ineffective assistance for not introducing favorable medical-record excerpts	Counsel performed deficiently by not admitting New York medical-record portions documenting hallucinations/paranoia	Counsel made a reasonable strategic choice to avoid opening adverse portions and risk State rebuttal under rule of completeness	Performance was not objectively unreasonable; claim fails under Strickland
Sufficiency of evidence (implicit)	(not contested)	State relied on eyewitnesses, statements, and conduct after shooting	Evidence was sufficient to sustain convictions

Kirby v. State, 304 Ga. 472, 819 S.E.2d 468 (Ga. 2018) (sets three-part test for admission of other-act evidence and Rule 403 balancing factors)
Brown v. State, 303 Ga. 158, 810 S.E.2d 145 (Ga. 2018) (other-act evidence improper where defendant asserted self-defense and State’s need was minimal)
Olds v. State, 299 Ga. 65, 786 S.E.2d 633 (Ga. 2016) (intent is placed at issue when defendant pleads not guilty and asserts mental-state defenses)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of evidence review)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel)