Gibson v. State, 308 Ga. App. 63

Gibson was charged along with three co-defendants in a single drug-related case based on drugs found in a car they occupied.
The car occupants were Fabian (driver), Vines (front passenger), Gibson (right rear), Cohen (behind the driver).
Officers detected an overwhelming odor of marijuana; a backpack in the car contained crack cocaine, powder cocaine, MDMA, marijuana, ammunition, and weapons.
Gibson admitted ownership of a Glock and a Hi-Point pistol; Cohen admitted the Taurus pistol belonged to him.
Gibson claimed he did not know about the drugs and that a piece of paper with his girlfriend’s address was not his, though it was found in the backpack.
During trial, Cohen’s counsel questioned Gibson about potential sentences; the trial court halted the line of questioning and later issued a curative instruction, but Gibson did not pursue further objections or mistrial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Gibson received ineffective assistance based on trial counsel's handling of sentencing questioning	Gibson argues counsel failed to object or move for mistrial regarding sentencing questions.	Gibson contends that objections were inadequate and the mistrial/curative instructions were insufficient.	No reversible error; insufficient showing of prejudice; judgment affirmed.

Perkins v. State, 288 Ga.App. 802 (Ga.App. 2007) (prohibition on evidence about specific sentences unless deal exists)
Howard v. State, 286 Ga. 222 (Ga. 2009) (curtailment of improper sentencing references)
Vogleson, 275 Ga. 637 (Ga. 2002) (exception permitting sentence information on cross-examination only for deals)
Cloud v. State, 136 Ga.App. 244 (Ga.App. 1975) (sentencing references generally prohibited in guilt phase)
Miller v. State, 285 Ga. 285 (Ga. 2009) (ineffective assistance standard (Strickland))
Moore v. State, 228 Ga. 662 (Ga. 1972) (prior formulation on punishment consideration)