Chambers v. State, 313 Ga. App. 39

Chambers was convicted of first-degree cruelty to children under OCGA § 16-5-70(b).
The six-year-old victim stayed overnight October 8, 2006 at Chambers's house.
Chambers whipped the child with a telephone cord, leaving wounds on the back, buttocks, thighs, and groin.
The mother attempted to treat the injuries and eventually took the child to the emergency room after hurting her toe.
Emergency room professionals testified the wounds were not bleeding and were likely a few days old, with a nurse noting dry blood present.
The trial court asked questions of the nurse to clarify timing of the bleeding; Chambers's motion for new trial was denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Chambers	Chambers	Evidence supports conviction
OCGA § 17-8-57 compliance	Chambers contends improper court comment	State argues questions were permissible to develop truth	No abuse; questions were objective and clarifying
Ineffective assistance of counsel	Chambers argues counsel failed to develop credibility issues	Counsel reasonably attacked credibility; no prejudice shown	Counsel not ineffective; no prejudice shown

Reese v. State, 270 Ga.App. 522 (2004) (standard of review for sufficiency of evidence in criminal appeals)
Jackson v. Virginia, 443 U.S. 307 (1979) (rational juror could find elements beyond a reasonable doubt)
Dickens v. State, 280 Ga. 320 (2006) (trial court may pose questions to develop truth without improper implication)
Curry v. State, 283 Ga. 99 (2008) (questions must be entirely objective and related to events)
Suggs v. State, 272 Ga. 85 (2000) (ineffective assistance requires deficient performance and prejudice)
Strickland v. Washington, 466 U.S. 668 (1984) (standard for evaluating ineffective assistance of counsel)
Lyons v. State, 269 Ga. App. 27 (2004) (cumulative evidence rule in ineffective assistance analysis)
Dinkler v. State, 305 Ga. App. 444 (2010) (sufficiency and credibility considerations in appellate review)