Goodrum v. State, 303 Ga. 414

In Dec. 2014, at a house party, Goodrum got into an altercation with Tarvanisha Boyd and then shot her; Boyd later died of a chest wound. Goodrum fled, crashed his car, and was shortly thereafter detained; he smelled of alcohol.
Investigators found various cartridge casings near the scene and a possible bullet hole in Goodrum’s car. Four eyewitnesses testified no one but Goodrum had a gun.
Goodrum testified at trial claiming self-defense and that someone had handed Boyd a gun.
A jury acquitted Goodrum of malice murder but convicted him of felony murder (predicated on aggravated assault), related firearm and driving counts; he was sentenced to life without parole plus additional terms.
On appeal Goodrum raised: (1) violation of his state constitutional right to be present when a juror was excused during a bench discussion held in chambers while he was absent, and (2) ineffective assistance of trial counsel for failing to object to portions of the prosecutor’s closing argument.

Issue	Goodrum's Argument	State's Argument	Held
Whether Goodrum's right to be present was violated when a juror (Tullis) was excused during a discussion in chambers while Goodrum was absent	Goodrum: exclusion from the juror-removal discussion violated his constitutional right to be present at critical stages	State: Goodrum acquiesced to his absence (no contemporaneous objection); counsel handled matters and an alternate was available	Court: Goodrum acquiesced to counsel’s waiver; no reversible violation given his silence and lack of objection
Whether trial counsel was ineffective for not objecting to prosecutor’s remark that Goodrum would have called 911 if he acted in self-defense	Goodrum: counsel’s failure to object was deficient and prejudicial under Strickland	State: counsel’s choice was a strategic decision—responding in his own closing—and not objectively unreasonable	Court: No ineffective assistance; counsel’s tactic was reasonable and not patently unreasonable

Jackson v. Virginia, 443 U.S. 307 (legal-sufficiency standard for convictions)
Strickland v. Washington, 466 U.S. 668 (test for ineffective assistance of counsel)
Williams v. State, 300 Ga. 161 (defendant’s waiver/acquiescence to absence must be express or acquiesced)
Burney v. State, 299 Ga. 813 (acquiescence may be found from silence after being informed of proceedings)
Ward v. State, 288 Ga. 641 (acquiescence requires knowledge of proceedings)
Zamora v. State, 291 Ga. 512 (defendant entitled to be present when juror removed)
Simmons v. State, 299 Ga. 370 (strong presumption counsel acted reasonably)
Mallory v. State, 261 Ga. 625 (rule on commenting on pre-arrest silence)
Hartsfield v. State, 294 Ga. 883 (objective-reasonableness inquiry for counsel’s failure to object)
Smith v. State, 296 Ga. 731 (tactical silence during prosecution’s theatrics can be reasonable)
Heywood v. State, 292 Ga. 771 (distinguishing purely legal bench conferences from juror-removal discussions)