Charleston v. State, 292 Ga. 678

Appellant Maurice Charleston and Scott Walker were indicted for malice murder and related crimes for the death of Edric Finney.
A joint trial resulted in guilty verdicts for both defendants; Walker’s convictions were previously affirmed.
Finney was shot by a single close-range shotgun blast at Pamela Lyman’s apartment; two off-duty officers witnessed the aftermath.
Witnesses linked Charleston and Walker to Finney at Lyman’s apartment and described discussions about a gun and payment.
Police later arrested Charleston and Walker; Walker was found hiding under mattresses in Charleston’s father’s home.
On appeal, the Court affirms Charleston’s convictions and addresses discovery, severance, ineffective assistance, and newly discovered evidence claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence	Charleston asserts insufficient evidence to convict as a party to the crimes.	Walker argues the evidence fails to prove Charleston’s participation.	Sufficient evidence supports guilt as a party.
Discovery/ Brady violation	Failing to list Jonathan Finney violated OCGA § 17-16-3; Brady claim raised.	State violated discovery; Brady claim should undermine conviction.	No reversible discovery/ Brady error; barred on failure to raise timely; no Brady violation.
Severance	Joint trial should have been severed due to potential antagonism of defenses.	Severance proper; defenses not antagonistic and case straightforward.	No abuse of discretion; severance denied.
Ineffective assistance of counsel	Counsel failed at multiple points, including evidentiary objections and suppression strategy.	Counsel acted reasonably; no prejudice shown; strategic decisions.	Claims evaluated under Strickland; no deficient performance with prejudice shown.
Newly discovered evidence	Walker’s unsworn statement at sentencing constitutes newly discovered evidence.	Evidence fails Rules for newly discovered evidence; sworn affidavit missing.	Motion properly denied; lack of sworn affidavit and other requirements unmet.

Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (sufficiency of the evidence standard)
Bell v. Cone, 535 U.S. 685 (U.S. Supreme Court 2002) (limited Cronic prejudice standard; complete failure required)
Turpin v. Curtis, 278 Ga. 698 (Ga. 2004) (constructive denial of counsel requires complete failure)
Brown v. State, 288 Ga. 902 (Ga. 2011) (trial strategy as defense tactic; lack of counsel testimony)
Lynch v. State, 291 Ga. 555 (Ga. 2012) (prejudice inquiry under Strickland partial withholding evidence)
State v. Palmer, 285 Ga. 75 (Ga. 2009) (search warrant probable cause despite some inaccuracies)
Higuera-Hernandez v. State, 289 Ga. 553 (Ga. 2011) (discretionary continuance for discovery violations)
Brady v. Maryland, 373 U.S. 83 (U.S. Supreme Court 1963) (exclusionary rule for suppression of exculpatory evidence)