Collins v. State, 306 Ga. 464

On May 2, 2013, Casey Collins and Sarah Cook, both opioid users who bought pills from Collins’s grandfather Edward Ronald Smith, confronted Smith after he refused to "front" them pills; Cook stabbed Smith and Collins strangled him with a belt. Collins took Smith’s wallet and pills and the couple spent the money that day.
Cook later confessed, led police to Smith’s truck and body, and testified against Collins; medical examiner ruled death by manual strangulation with a ligature; stabbing wounds were nonfatal.
A Cobb County jury convicted Collins of malice murder, armed robbery, aggravated assault, and concealing a death; he received life without parole for malice murder plus additional sentences. Collateral counts were merged or vacated.
Collins appealed claiming ineffective assistance of counsel for (1) failing to investigate/present evidence that Smith sexually abused Collins as a child (causing PTSD) to support a voluntary manslaughter instruction, and (2) failing to withdraw after Collins filed a bar complaint against trial counsel.
The trial court denied relief; the Georgia Supreme Court reviewed Strickland standards and Georgia precedents on provocation/voluntary manslaughter and conflicts of interest and affirmed Collins’s convictions.

Issue	Collins’s Argument	State’s Argument	Held
Whether counsel was ineffective for not investigating/presenting evidence of childhood sexual abuse/PTSD to obtain a voluntary manslaughter instruction	Counsel should have investigated and introduced abuse/PTSD evidence to show provocation or diminished control, warranting voluntary manslaughter	Evidence of subjective mental condition/PTSD is irrelevant to the objective provocation standard for voluntary manslaughter; investigation would be futile	Denied — counsel’s failure not deficient or prejudicial; provocation is judged objectively and prior abuse years earlier does not support voluntary manslaughter instruction
Whether counsel was ineffective for not withdrawing after Collins filed a bar complaint alleging ethical violations	Counsel should have withdrawn due to an implied conflict following the bar complaint	A bar complaint alone does not create an automatic disqualifying conflict; no actual conflict shown and Collins later affirmed satisfaction with counsel	Denied — no actual conflict that adversely affected performance; withdrawal not required

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
Strickland v. Washington, 466 U.S. 668 (ineffective assistance two-prong test)
Prothro v. State, 302 Ga. 769 (Georgia law on objective provocation standard)
Lewandowski v. State, 267 Ga. 831 (expert testimony on defendant’s mental state irrelevant to voluntary manslaughter)
Partridge v. State, 256 Ga. 602 (objective standard for provocation excludes subjective mental fragility)
Huff v. State, 292 Ga. 535 (reinforcing limits on mental-condition evidence for manslaughter)
Cochran v. State, 305 Ga. 827 (discussion on admissibility and relevance of mental-condition evidence)
Virger v. State, 305 Ga. 281 (mental-condition evidence and criminal intent)
Strickland-related Georgia cases on counsel performance: Barrett v. State, 292 Ga. 160; Davis v. State, 299 Ga. 180 (standards for assessing counsel performance and prejudice)
Mangrum v. State, 291 Ga. 529 (speculation insufficient to show prejudice from missing medical/testimony evidence)
Johnson v. State, 297 Ga. 839 (interval between provocation and killing defeats manslaughter claim)
Holsey v. State, 291 Ga. App. 216 (bar complaint alone does not establish a conflict requiring withdrawal)
Tanner v. State, 303 Ga. 203 (actual conflict requirement for Sixth Amendment claim)
Mickens v. Taylor, 535 U.S. 162 (definition of actual conflict of interest)