Grant v. State, 295 Ga. 126

In December 2007, Devon Grant shot and killed Kattilius “Deebo” Middlebrooks after an earlier dice-game dispute during which Grant threatened to kill Middlebrooks.
An eyewitness identified Grant as the shooter; Grant made post-shooting statements to family and others admitting he shot someone named Deebo over a dice game.
Grant was indicted for murder and related offenses, tried in June 2009, convicted of malice murder and possession of a firearm during a crime, sentenced to life plus five years, and moved for a new trial (denied).
On appeal Grant challenged: (1) sufficiency of evidence, (2) Brady violation for late disclosure of a videotaped interview implicating another suspect (Ledell Ellis), (3) courtroom closure and the trial court’s handling of jury notes requesting rehearing of testimony, and (4) several ineffective-assistance-of-counsel claims (including failure to raise Batson, failure to obtain a leniency charge, and inadequate witness investigation).
The Georgia Supreme Court reviewed the record, applying Jackson v. Virginia for sufficiency and Strickland for ineffective assistance, and affirmed the convictions.

Issue	Grant's Argument	State's Argument	Held
Sufficiency of the evidence	Evidence was insufficient to prove guilt beyond a reasonable doubt	Eyewitness ID, admissions, and circumstantial proof support conviction	Affirmed; evidence sufficient under Jackson v. Virginia
Brady nondisclosure (Gardner videotape implicating Ellis)	Late disclosure deprived defense of exculpatory material that might have produced a different outcome	File included other documents eliminating Ellis; late item was cumulative and not likely to change outcome	No reversible Brady error; no reasonable probability of different result
Jury communications & rehearing testimony	Trial court failed to follow Lowery procedures and improperly refused to allow rehearing	Court read notes aloud, conferred with counsel, allowed input, and properly exercised discretion to deny rehearing	No reversible error: procedural defects caused no harm and denial of rehearing was within discretion
Ineffective assistance (Batson; leniency charge; preparation/interviews)	Counsel should have raised Batson, requested leniency charge, and investigated more witnesses	No prima facie Batson proof in record; leniency charge unsupported by evidence; no proffer of favorable witnesses from further investigation	Ineffective-assistance claims fail: either meritless or no Strickland prejudice shown

[Jackson v. Virginia, citation="443 U.S. 307"] (establishes standard for sufficiency of evidence review)
[Brady v. Maryland, citation="373 U.S. 83"] (prosecution duty to disclose exculpatory evidence)
[Kyles v. Whitley, citation="514 U.S. 419"] (Brady materiality standard — reasonable probability of a different result)
[Strickland v. Washington, citation="466 U.S. 668"] (two-prong test for ineffective assistance)
[Batson v. Kentucky, citation="476 U.S. 79"] (prohibits race-based peremptory strikes)
[Lowery v. State, citation="282 Ga. 68"] (procedures required for handling juror communications)
[Lane v. State, citation="268 Ga. 678"] (requested jury charge must be authorized by evidence)
[Humphreys v. State, citation="287 Ga. 63"] (harm required to reverse procedural errors involving jury notes)
[Blackshear v. State, citation="285 Ga. 619"] (Brady/materiality discussion in Georgia context)
[Burtts v. State, citation="269 Ga. 402"] (trial court discretion to deny jury rehearing of testimony)