Enuka v. State, 314 Ga. App. 466

Enuka received a past-due rent notice and called management to dispute payment tracing.
Staff explained the burglarized drop box complicated tracing; Enuka became verbally abusive and refused to leave.
Enuka drove to the office, yelled at staff, and demanded contact with police; he later returned and threatened Wheeler.
Police blocked Enuka’s car; he was arrested after questioning; charged with terroristic threats, criminal trespass, and disorderly conduct.
Jury acquitted on all counts except terroristic threat; motion for new trial denied; appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for terroristic threat	Enuka argues evidence insufficient to prove threat.	State argues threat was credible and communicated.	Evidence sufficient to support threat conviction.
Effectiveness of trial counsel	Enuka contends counsel failed to investigate burglary and plea.	State asserts counsel acted diligently; no failure shown.	Counsel's performance not deficient; no reasonable probability of different outcome.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard; review in light of prosecution evidence)
Mickens v. State, 277 Ga. 627 (Ga. 2004) (credibility determinations reserved to jury)
Hamrick v. State, 304 Ga. App. 378 (Ga. App. 2010) (weighing credibility; appellate deference to jury)
Moore v. State, 234 Ga. App. 332 (Ga. App. 1998) (threats sufficient to constitute terroristic threat)
Stone v. State, 210 Ga. App. 198 (Ga. App. 1993) (terroristic threat defined)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-pronged deficient-performance standard)
Williams v. State, 277 Ga. 853 (Ga. 2004) (application of Strickland standards in Georgia)
Robinson v. State, 277 Ga. 75 (Ga. 2003) (independent review of trial court findings)
Badger v. State, 310 Ga. App. 157 (Ga. App. 2011) (communication of plea offers and defense strategy)