Compton v. Jackson, 295 Ga. 777

Compton was convicted of murder; this Court affirmed his convictions and sentences on direct appeal.
He filed a habeas petition (pro se in 2007, amended in 2012) asserting ineffective assistance of trial counsel based on: (1) counsel’s failure to object to a juror being excused after an unrecorded in-chambers conversation; and (2) counsel’s failure to be present for the judge’s out-of-court consultations with jurors.
On the third day of deliberations, Juror White told the judge in chambers (first unrecorded, then in a later recorded colloquy) she could not reach a verdict and could not continue; the judge excused her and seated an alternate, then instructed the jury to restart deliberations.
Neither trial counsel nor the State objected at trial to the in-chambers discussion or Juror White’s dismissal; Compton later claimed counsel was ineffective for failing to object and preserve the issue.
The habeas court held Compton failed to show prejudice from counsel’s alleged failures and that the trial judge acted within discretion in dismissing the juror; it denied relief. The Supreme Court of Georgia affirmed.

Issue	Compton's Argument	State's Argument	Held
Whether counsel was ineffective for failing to object to the in-chambers juror discussion and excusal	Counsel’s absence and failure to object deprived Compton of a record and the chance to keep Juror White, who Compton contends was voting not to convict	The judge had discretion to dismiss a juror unable to perform duties; counsel’s failure to object did not cause prejudice	Court held no prejudice shown; judge did not abuse discretion in excusing juror, so habeas relief denied

Strickland v. Washington, 466 U.S. 668 (establishes two-pronged ineffective assistance standard of deficient performance and prejudice)
Compton v. State, 281 Ga. 45 (affirmed convictions on direct appeal; defendant waived appellate challenge by failing to object at trial)
Reid v. State, 286 Ga. 484 (prejudice is not presumed for structural errors in ineffective-assistance claims)
Brooks v. State, 281 Ga. 14 (standard for ineffective assistance where counsel fails to object to replacement of a juror)
Walker v. Houston, 277 Ga. 470 (court may dispose of ineffective-assistance claim on prejudice ground without addressing performance)
Henderson v. Hames, 287 Ga. 534 (appellate review accepts habeas court factual findings but independently applies law)
Smith v. State, 284 Ga. 17 (trial court has statutory discretion to discharge and replace a juror when legally justified)