Green v. State, 300 Ga. 707

Willie Moses Green stabbed Marita Bradshaw to death in November 2004; autopsy showed 18 stab wounds consistent with a screwdriver. Green confessed to police at the scene and in a recorded interview.
Green had a lengthy psychiatric history; he was found incompetent after an initial evaluation, committed to a state hospital, later found competent and returned for trial, and a jury at a competency trial found him competent.
At trial Green pursued an insanity defense and presented expert testimony that he suffered delusions (lightning emanating from the victim) that compelled the killing; the State’s expert attributed the homicide to anger, not a delusion-driven compulsion.
During voir dire Green repeatedly disrupted the courtroom and was removed twice; after one removal the judge told the jury that Green had recently been found competent to stand trial.
The jury convicted Green of malice murder and found him guilty but mentally ill; he was sentenced to life imprisonment. Green appealed, arguing (1) trial-court error in handling his outbursts, (2) error in the judge’s comment about competency without distinguishing sanity, and (3) ineffective assistance of counsel.

Issue	Plaintiff's Argument (Green)	Defendant's Argument (State)	Held
Whether denial of mistrial after first outburst was error	Court should have declared mistrial because outburst prejudiced jury	Trial court acted within discretion by removing Green and briefly explaining to jurors; mistrial unnecessary	No reversible error; judge’s handling was reasonable and discretionary
Whether judge’s statement that Green had been found competent (without explaining competency vs. sanity) was prejudicial	Comment likely confused jurors and prejudiced Green’s insanity defense	Defense did not object at trial; any possible confusion was cured as experts later explained competency vs. sanity	Issue not preserved; even if reviewed, no reversible error because trial testimony clarified the legal distinction
Whether trial counsel was ineffective for failing to object to judge’s competency remark (and other unspecified matters)	Counsel’s failures deprived Green of effective assistance	Only specific alleged deficiency was failure to object to the competency comment; because no error, failure to object caused no prejudice	Ineffective-assistance claim rejected; defendant did not identify a professionally deficient act causing prejudice

Jackson v. Virginia, 443 U.S. 307 (review of legal sufficiency of evidence) (jury verdict must be upheld if evidence permits a rational trier of fact to find guilt beyond a reasonable doubt)
Choisnet v. State, 295 Ga. 568 (insanity defense may be rejected by jury despite evidence of mental illness)
Messer v. State, 247 Ga. 316 (trial court has discretion in responding to courtroom demonstrations and outbursts)
Strickland v. Washington, 466 U.S. 668 (two-prong test for ineffective assistance: deficient performance and prejudice)
Romer v. State, 293 Ga. 339 (standard for assessing deficient performance of counsel)
King v. State, 286 Ga. 721 (errors not raised at trial generally not preserved on appeal)
State v. Gardner, 286 Ga. 633 (court comments that effectively resolve matters previously decided by another jury are not necessarily improper)