Daughtry v. State, 296 Ga. 849

Background

Ricardo Daughtry was indicted for malice murder (and related homicide counts) for the June 16–17, 2007 shooting death of William Watson, and for possession of cocaine and obstruction of an officer from September 11, 2007. He was convicted on all counts and sentenced to life plus additional terms.
Evidence: Watson found shot multiple times in his bathtub; five shell casings and bullets at scene; cocaine residue and smoking paraphernalia in apartment; Appellant’s fingerprints on a plate in the kitchen; Watson’s phone showed a call at 12:45 a.m. from Appellant’s number.
Witness and corroborating evidence: Jeremy Williams and others testified implicating Daughtry; Williams heard Daughtry admit shooting Watson; surveillance/receipt showed Daughtry bought a black light after investigators called his number; a .380 handgun (serial scratched) recovered from the Ogeechee River matched casings from the scene and was identified by witnesses as Daughtry’s.
Post-arrest events: On Sept. 11, 2007 officers arrested Daughtry at his grandmother’s home; a bag of crack cocaine was found on him during that arrest. Daughtry denied involvement in the murder and denied having the phone, gun, or visiting Lowe’s.
Procedural posture: Trial counsel raised multiple defenses but did not pursue several motions/objections Daughtry now argues were constitutionally ineffective; trial court denied a new trial; Georgia Supreme Court reviews ten ineffective-assistance claims and affirms conviction.

Issues

Issue	Daughtry's Argument	State's Argument	Held
Severance of Sept.11 offenses from homicide charges	Counsel should have moved to sever because the Sept.11 crimes (cocaine/obstruction) were unrelated and occurred at arrest	Record shows Daughtry was arrested for homicide-related crimes on Sept.11; crimes at arrest are related and joinder appropriate	No deficient performance; joinder was proper and motion to sever not plainly required
Motion to suppress cocaine found at arrest	Counsel should have moved to suppress cocaine on grounds it was found incidentally and not tied to homicide arrest	Officer testimony established lawful arrest for homicide and search incident to arrest justified the seizure	No deficient performance; suppression motion would likely fail
Challenge to similar transaction evidence (May 13 robbery)	Counsel should have excluded evidence of a May 13 shooting/robbery as irrelevant and prejudicial	Evidence tended to show possession of same murder weapon earlier and was relevant to identity	No deficient performance; evidence admissible to show identity/possession and counsel’s tactics reasonable
Failure to call/introduce certain witnesses or impeachment (Cheevers, Sheppard, Oliver, prior inconsistent statements)	Counsel failed to call exculpatory witness (Cheevers) and failed to impeach with prior inconsistent statements or pending charges	Cheevers’ testimony would not have overcome strong timeline/evidence; impeachment claims lacked admissible support or were cumulative	No prejudice shown; even assuming some lapse, overwhelming evidence of guilt defeats Strickland prejudice requirement

Key Cases Cited

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)
Benford v. State, 272 Ga. 348 (admission of circumstances of arrest and related evidence)
Woolfolk v. State, 282 Ga. 139 (joinder upheld where one crime is circumstance of arrest for another)
Roundtree v. State, 270 Ga. 504 (related-offense joinder principles)
Bester v. State, 294 Ga. 195 (burden and review of ineffective-assistance claims)
Schofield v. Holsey, 281 Ga. 809 (procedural considerations in ineffectiveness review)
Renner v. State, 260 Ga. 515 (disapproval of flight jury charge reasoning cited on related charge issues)
Perera v. State, 295 Ga. 880 (no duty to anticipate changes in law; counsel not ineffective for failing to make meritless objections)
State v. Worsley, 293 Ga. 315 (deference to trial counsel tactical choices)