Glenn v. State, 296 Ga. 509

On August 26–27, 2011, James Michael Glenn III and Aaron Weeks had an altercation with Cliff Brannon after Brannon drove close to them and yelled racial slurs; Glenn later fired shots at Brannon’s vehicle and left the scene.
Six .25 caliber shell casings from Glenn’s pistol were found 150 feet from Brannon’s house; Brannon was shot multiple times, transported to a hospital, and died September 2, 2011.
Glenn told others he had killed someone; his roommate reported Glenn’s statements to police; Glenn testified at trial that he shot Brannon in self-defense after being attacked and believing Brannon had a weapon.
A Clayton County jury acquitted Glenn of malice murder but convicted him of felony murder (during aggravated assault), aggravated assault (merged), and possession of a firearm during a crime; Glenn received life plus five years.
In post-trial proceedings, Glenn argued (1) insufficiency of the evidence because the State failed to disprove his self-defense justification and (2) ineffective assistance because trial counsel did not object to Brannon’s mother identifying a pre-death photograph.

Issue	Plaintiff's Argument (Glenn)	Defendant's Argument (State)	Held
Sufficiency of evidence / self-defense	State failed to disprove Glenn’s claim of justification; his testimony described a defensive struggle and perceived weapon	Evidence of prior threats, revenge motive, shots fired at vehicle, wounds including shot in back, and shell casings tied to Glenn supported the jury’s rejection of self-defense	Conviction affirmed: jury could reject self-defense and find guilt beyond reasonable doubt (Jackson review applies)
Ineffective assistance — failure to object to victim-photo ID by mother	Counsel was deficient for not objecting to the mother identifying a photo, which risked emotional prejudice	Counsel reasonably focused on self-defense theory; mother did not become emotional and no prejudice shown	No ineffective assistance: performance not shown to be deficient or prejudicial; motion for new trial properly denied

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence review)
Crane v. State, 281 Ga. 635 (placing burden on State to disprove asserted justification)
Greeson v. State, 287 Ga. 764 (deference to jury on credibility and weight of evidence)
Tolbert v. State, 282 Ga. 254 (jury resolves conflicts in evidence)
Roper v. State, 281 Ga. 878 (jury may reject defendant’s version of events)
Smith v. Francis, 253 Ga. 782 (Strickland two-prong test for ineffective assistance)
Strickland v. Washington, 466 U.S. 668 (establishing deficient performance and prejudice framework)
Robinson v. State, 277 Ga. 75 (appellate review accepts trial court’s factual findings)
Ledford v. State, 264 Ga. 60 (admissibility of victim photographs; caution about family-member identification)
Kilpatrick v. State, 276 Ga. 151 (no harm where family-member identification produced no emotional outburst)
Reaves v. State, 292 Ga. 545 (party asserting error must produce evidence at hearing)
Malcolm v. State, 263 Ga. 369 (merger principles for convictions)