Dunlap v. State, 291 Ga. 51

Dunlap was convicted of felony murder of Burmese immigrant Tial Ceu during a planned DeKalb County robbery.
On April 1, 2008, Dunlap and associates scoped victims, robbed Ceu of $70, and Dunlap shot Ceu in the chest, causing death at the scene.
A witness identified Dunlap in a photo lineup and testified he appeared to be the gunman while seen fleeing to a getaway car.
An in-custody statement admitted Dunlap intended to rob, witnessed the shooting, and aided his accomplices in leaving; he denied participating in the shooting.
Appeal challenged evidence sufficiency, suppression of statements after an alleged invocation of counsel, and defense counsel’s failure to transcribe voir dire and opening/closing arguments.
The Supreme Court of Georgia affirmed, holding sufficient evidence, no error in suppression ruling, and no ineffective assistance from trial counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence sufficient for felony murder?	Dunlap challenged sufficiency to prove felony murder beyond a reasonable doubt.	State contends the evidence supported guilt beyond a reasonable doubt.	Sufficiency established; rational trier could convict.
Did the in-custody statements get improperly suppressed for an equivocal request for counsel?	Dunlap invoked right to counsel and interrogation should have ceased.	Requests were equivocal; interrogation permissible after Miranda waiver.	No error; invocation was equivocal, so police could continue.
Was trial counsel ineffective for not transcribing voir dire and opening/closing?	Failure to transcribe could prejudice and undermine defense.	Transcripts of such proceedings are not required in non-death penalty cases; practice reasonable.	No ineffective assistance; trial counsel's practice was reasonable.
Did the court abuse discretion in new-trial ruling on these issues?	Motion for new trial should have been granted based on alleged deficiencies.	No reversible error given applicable legal standards and record.	Trial court did not err; judgment affirmed.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review standard for convicting a defendant)
Robinson v. State, 286 Ga. 42 (Ga. 2009) (unambiguous request for attorney halts interrogation)
Crawford v. State, 288 Ga. 425 (Ga. 2011) (equivocal invocation of counsel does not force cessation of questioning)
Pruitt v. State, 282 Ga. 30 (Ga. 2007) (ineffective assistance standard and prejudice burden)
State v. Graham, 246 Ga. 341 (Ga. 1980) (voir dire transcription not required absent death penalty)
Jackson v. Denno, 378 U.S. 368 (U.S. 1964) (pretrial determination of voluntariness of statements)