Davis v. State, 290 Ga. 584

Davis was convicted of felony murder for the November 27, 2008 death of Roy Robinson.
At trial, Davis, Robinson, Luke, and Lowe were drinking; a fight ensued after Davis was struck with a shattered glass and Davis retrieved a knife.
Robinson advanced with a couch cushion threatening Davis; Davis chased and stabbed Robinson in the hallway; no weapon remained on Robinson.
Davis claimed self-defense; police recovered the knife; witnesses identified Davis as the assailant.
The jury heard evidence supporting self-defense but also evidence sufficient to convict; the standard was whether there was sufficient evidence for a rational jury to convict beyond a reasonable doubt.
Post-trial, Davis challenged trial counsel's effectiveness (failure to call a defense expert and the decision to play a videotaped interrogation) and raised a juror-incident issue; the trial court denied relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the felony murder verdict supported by sufficient evidence?	Davis argues evidence favored self-defense and undermined felony murder.	State contends the evidence was sufficient to support guilt beyond a reasonable doubt.	Yes; evidence authorized a reasonable jury to convict.
Was trial counsel ineffective for not calling a defense expert about defensive wounds?	Expert could refute the medical examiner and corrobor self-defense.	Strategic choice; existing experts were equivocal; no prejudice established.	No; counsel's strategic decision was reasonable and not prejudicial.
Was trial counsel ineffective for introducing the videotape of the interrogation?	Tape aided self-defense narrative and should have been handled differently.	Introduction was a reasonable tactical decision to present the defense.	No; reasonable trial strategy supported introduction of the videotape.
Did the trial court err by not polling jurors after a juror's medical event?	Court should poll to ensure continued impartiality.	Failure to object at the time constitutes waiver.	Waived; appellate review denied.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence governs due-process standard)
Taylor v. State, 252 Ga. 125 (Ga. 1984) (jury may infer self-defense from evidence)
Thomas v. State, 239 Ga. 734 (Ga. 1977) (self-defense is for the jury to decide from the evidence)
Pruitt v. State, 282 Ga. 30 (Ga. 2007) (ineffective assistance requires deficient performance and prejudice)
Hendricks v. State, 290 Ga. 238 (Ga. 2011) (equivocal expert testimony can defeat ineffectiveness claim)
Bowie v. State, 286 Ga. 880 (Ga. 2010) (trial strategy decisions not ineffective assistance)
Slade v. State, 270 Ga. 305 (Ga. 1998) (trial strategy not evaluated by hindsight)
Sledge v. State, 312 Ga. App. 97 (Ga. App. 2011) (review of strategic decisions in trial conduct)