Goodman v. State, 742 S.E.2d 719

Goodman, Dressier, and Richardson, all from Virginia, conspired to murder Dressier after planning to kill Dressler by poisoning and strangulation.
Dressler’s husband was killed; Richardson later pled guilty to voluntary manslaughter and testified for Goodman.
Forensic evidence showed Dressier died by ligature strangulation; DNA on yarn matched Dressier, not others.
Trial occurred at the former Morgan County Senior Center due to courthouse renovations; Goodman’s consent to trial location was not obtained.
USCR 31.1/31.3 notice issues were raised; defense argued improper admission of evidence related to Dressler’s husband’s murder.
Richardson’s statements implicated Goodman, and multiple witnesses testified about Goodman’s behavior and role in the killings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence to sustain the convictions?	Goodman argues evidence supports the verdicts.	State contends evidence proves guilt beyond reasonable doubt.	Yes; evidence authorized jury verdicts beyond reasonable doubt.
Was trial held in an improper facility without defendant’s consent?	Consent was not established; trial location violated OCGA 15-6-18.	State argues harmless error; Purvis requires consent be on record.	Error occurred; harmless as to result; not reversible per Purvis analysis.
Did lack of USCR 31.1/31.3 notice render admissible evidence improper?	Waiver and motive evidence render proceedings admissible.	Lack of notice violated rules and prejudiced Goodman.	Evidence admissible; any notice defect non-prejudicial under cited authorities.
Was DNA testimony from yarn properly admitted given lack of explicit expert qualification?	No objection at trial; testimony should be excluded without proper qualification.	Waiver; Crosby’s testimony did not prejudice beyond scope of trial.	Review waived; no reversible error based on admissibility as preserved.
Did defense counsel’s handling of cross-examinations and closing argument amount to ineffective assistance?	Counsel failed to object to several improper statements.	Tactics were reasonable; objections would not have changed outcome.	No reasonable probability that result would differ; no ineffective assistance.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard for constitutional claims)
Purvis v. State, 288 Ga. 865 (2011) (consent for trial location must be shown on the record; harmless error analysis applied)
Lindsey v. State, 282 Ga. 447 (2007) (motive evidence relevant and admissible in homicide prosecutions)
Young v. State, 281 Ga. 750 (2007) (motive evidence admissible; relevance to defendant’s culpability)
Fulton v. State, 278 Ga. 58 (2004) (motive evidence admissible; relevance to case)
Mason v. State, 274 Ga. 79 (2001) (prosecutor’s improper credibility-based comments need preservation to review)