Chapman v. State
290 Ga. 631
| Ga. | 2012Background
- Chapman was convicted of felony murder during arson and arson in the first degree for a fatal fire at a Haralson County duplex.
- The victim, Alice Jackson, inhabited one half of the duplex; Chapman and his girlfriend inhabited the other half with their children.
- Fire investigators concluded the blaze was intentionally set; Chapman was overheard making statements about burning the house and harming the landlord.
- Chapman’s son allegedly cried, saying his father planned to burn the house down; Chapman’s conduct prior to the fire showed escalating conflict with the landlord.
- Chapman challenged trial counsel’s effectiveness in a motion for new trial; the trial court denied relief and Chapman appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Chapman argues evidence supports acquittal. | State argues sufficient evidence supports felony murder and arson. | Evidence sufficient to sustain verdict. |
| Ineffective assistance—general claim | Chapman asserts counsel was ineffective under Strickland. | State contends no deficient performance or prejudice. | No ineffective assistance; standards not met. |
| Accelerant and defense preparation | Counsel failed to pursue accelerant evidence. | Counsel examined experts; accelerant issue defended at trial. | Not deficient; prejudice not shown. |
| Pre-trial polygraph and funding | Counsel should have pursued pre-trial polygraph for Chapman. | Funding and strategy prevented polygraph; hindsight not enough. | Not ineffective; no probable result change. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence for reasonable juror verdict)
- Handley v. State, 289 Ga. 786 (Ga. 2011) (independent appellate review of facts and credibility)
- Perkins v. Hall, 288 Ga. 810 (Ga. 2011) (abandoned claims on appeal are not pursued)
- Johnson v. State, 290 Ga. 382 (Ga. 2012) (burden on defendant to show deficient performance when questioning counsel)
- Harris v. State, 280 Ga. 372 (Ga. 2006) (hindsight not enough to establish ineffectiveness)
- Judkins v. State, 282 Ga. 580 (Ga. 2007) (reasonable time for investigation not shown to be deficient)
- Joiner v. State, 265 Ga. App. 395 (Ga. App. 2004) (futile continuance not ineffective assistance)
- McKinney v. State, 281 Ga. 92 (Ga. 2006) (polygraph evidence and stipulation considerations)
- Smith v. State, 288 Ga. 348 (Ga. 2010) (cumulative-error review limits)