Davis v. State, 295 Ga. 168

Davis was convicted after a jury trial of malice murder, three counts of felony murder, and related offenses for the November 28, 2009 shooting death of Robert Gresham; death involved two handguns and multiple gunshot wounds.
Gresham ran a car repair shop and sold marijuana from his property on Moreland Avenue; Alvin Shannon witnessed two masked men with guns at the shop.
Davis’s step-sister drove him, Threatt, and Wyche to Moreland Avenue in the early morning; Wyche later left them.
A black jacket with gunshot residue was found at Davis’s home, and a hat near the barbecue pit, identified as Davis’s and containing his DNA, connected him to the scene.
Davis briefly substituted retained counsel for appointed counsel mid-trial; he sought continuances, which the court denied once trial had begun.
After trial, Davis challenged both the continuance denial and the effectiveness of counsel; the Georgia Supreme Court affirmed the convictions and rejected the ineffective-assistance claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion denying a continuance mid-trial.	Davis contends substitution required delay; requests continuance.	Davis had opportunity to hire substitute counsel; not entitled to delay.	No abuse of discretion; continuance denied appropriately.
Whether Rasnick’s performance as appointed counsel was ineffective at various stages.	Rasnick failed to provide adequate discovery access and meet with Davis/Wyche; preparation deficiencies.	Rasnick did meet, investigate, and review; no prejudice shown.	No ineffective assistance; record supports trial counsel’s conduct.
Whether Winner’s performance as retained counsel was ineffective at trial.	Winner unprepared and slept during trial.	Winner was familiar with the case; prepared despite limited time.	No ineffective assistance; record and witnesses support trial representation.

Flowers v. State, 275 Ga. 592 (Ga. 2002) (reasonable diligence required; not a dilatory tactic to hire counsel)
Brown v. State, 278 Ga. 724 (Ga. 2004) (no automatic continuation in substitution; discretion to deny continuance)
Calloway v. State, 313 Ga. App. 708 (Ga. App. 2012) (denying motion for continuance after substitution not abuse of discretion)
Ruffin v. State, 283 Ga. 87 (Ga. 2008) (no magic time requirement for counsel-client meetings)
Wright v. State, 291 Ga. 869 (Ga. 2012) (appellate court reviews trial court findings de novo for law)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for conviction beyond a reasonable doubt)