Garrett v. State, 288 Ga. 269

Garrett was convicted of felony murder and possession of a firearm during a crime for the shooting death of Darcell Kitchens.
At bar confrontation, Garrett, intoxicated and armed, argued with Kitchens and they left the bar; an unidentified man joined and they allegedly double-teamed Kitchens.
Two shots were fired; one hit Kitchens in the chest and the other in the back; Kitchens died after returning to the bar.
Only the chest-entry bullet was recovered; State proved it was fired from Garrett's gun; Garrett gave a post-arrest statement admitting the shooting.
Evidence supported a rational jury verdict of felony murder and firearms possession; Garrett challenged the jury instruction on parties to a crime as incomplete.
Garrett argued trial counsel was ineffective for not objecting to the charged incomplete party-to-a-crime instruction; he also challenged the exclusion of evidence about a pre-incident argument with Rhine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the party-to-a-crime charge preserved for review?	Garrett argues the incomplete charge harmed him.	State contends lack of proper objection prevents review.	Not preserved for review.
Did counsel's failure to object to the party-to-a-crime charge amount to ineffective assistance?	Garrett claims inadequate objection changed outcome.	State argues no reasonable probability the result would differ.	Garrett fails to show reasonable probability of different outcome.
Was the exclusion of evidence about Rhine's pre-shooting argument proper?	Garrett sought to show justification or aggressor status.	Evidence not probative of justification; not shown as aggressor by victim.	No error; evidence properly excluded.
Was the evidence sufficient to sustain felony murder and firearms charges?	Evidence showed Garrett's participation and intent.	Challenged as to intent of aiding or abetting by third party.	Evidence sufficient beyond reasonable doubt.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard: rational trier of fact may find proof beyond reasonable doubt)
Jenkins v. State, 272 Ga. 250 (Ga. 2000) (preservation for charges requires proper objection)
Hill v. State, 284 Ga. 521 (Ga. 2008) (ineffective assistance framework; prongs pruned when prejudice shown)
Bailey v. State, 273 Ga. 303 (Ga. 2001) (prong requirement for Strickland; absence of prejudice ends inquiry)
Cox v. State, 242 Ga. App. 334 (Ga. App. 2000) (criminal liability for party to a crime; joint participation suffices)
Milner v. State, 281 Ga. 612 (Ga. 2007) (aggressor analysis; justification evidence considerations)
Laster v. State, 268 Ga. 172 (Ga. 1997) (relevance and justification requirements in admissibility decisions)