Glover v. State, 291 Ga. 152

Glover was convicted of malice murder and sentenced to life imprisonment for the killing of Willie Alexander; judgment and sentence entered November 1999.
The murder involved Glover chasing and shooting an unarmed victim after an incident over a cigarette; victim died from seven gunshot wounds.
Glover admitted to one witness that he shot the victim because he was mad.
A motion for new trial was filed December 1999, amended June 2010, and denied December 2010; appeal filed December 2010.
Glover challenged admissibility of victim’s prior acts and delayed post‑conviction review; the court addressed waiver, ineffective assistance, and due process delay claims.
Trial and appellate history culminated in a May 29, 2012 decision affirming the judgment, with the delay not violating due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there error for not holding a Rule 31.6 hearing?	Glover argues failure to hear and rule on admissibility of victim's prior acts violated Rule 31.6 (B).	Glover waived the hearing by failing to request one or raise the issue; trial counsel did not seek rulings.	Waiver; no reversible error.
Did trial counsel's handling render ineffective assistance?	Evidence of victim’s prior violence would corroborate self‑defense and undermine lack of justification.	Even if deficient, no reasonable probability the outcome would differ; overwhelming evidence supports guilt.	No prejudicial ineffective assistance.
Did appellate delay violate due process under Barker factors?	Long appellate delay prejudiced his rights and undermined defense ability.	Delay weighed against him, but no prejudice shown; factors do not establish due process violation.	Delay did not violate due process; four Barker factors weighed against relief.
Was the sufficiency of the evidence properly established?	Evidence including eyewitnesses supported a rational finding of malice murder.	No challenge adequately rebutted the sufficiency showing; we defer to jury's verdict.	Evidence was sufficient to support murder conviction.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for evaluating evidence)
Curry v. State, 283 Ga. 99 (Ga. 2008) (standard for review of evidence in Georgia)
Spencer v. State, 287 Ga. 434 (Ga. 2010) (Rule 31.6 hearing and admissibility procedures; waiver principle)
Brown v. State, 307 Ga. App. 99 (Ga. App. 2010) (waiver when no motion or objection preserved ruling)
Overton v. State, 270 Ga. App. 285 (Ga. App. 2004) (procedural waivers and appellate rulings in USCR context)
Cooper v. State, 279 Ga. 189 (Ga. 2005) (Strickland standard for ineffective assistance; prejudice required)
Johnson v. State, 266 Ga. 380 (Ga. 1996) (prejudice in ineffective assistance analysis)
Payne v. State, 289 Ga. 691 (Ga. 2011) ( appellate delay due process Barker factors framework)
Chatman v. Mancill, 280 Ga. 253 (Ga. 2006) (application of Barker factors to appellate delay; prejudice considerations)
Owens v. State, 286 Ga. 821 (Ga. 2010) (extension of Barker factors; prejudice and delay analysis)
Loadholt v. State, 286 Ga. 402 (Ga. 2010) (weighing Barker factors; delay not reversible error)
Shank v. State, 290 Ga. 844 (Ga. 2012) (prejudice and due process in appellate delay)
Pineda v. State, 288 Ga. 612 (Ga. 2011) (prejudice standard in appellate delay challenges)