Grier v. State, 305 Ga. 882

On Oct. 4, 2013, Lamaris Grier was present at Jerry Grier's house in the morning; later that day Jerry and Jamanius Mills were found shot dead in Jerry's home.
Witnesses placed Grier alone with the victims shortly before the killings; cell‑site data placed Grier in the area that morning; Grier allegedly told a friend he had "offed them boys."
Police recovered .40 caliber casings and bullet fragments; Grier was known to carry a Glock .40.
Grier was indicted on multiple counts including malice murder and was convicted by a jury in May 2015; sentenced to concurrent life terms for malice murder plus a consecutive five‑year term for a firearm offense.
On appeal Grier argued (1) insufficient evidence, (2) ineffective assistance for failure to object to lay‑opinion testimony and a prosecutor comment about Rule 404(b) evidence, and (3) prosecutorial misconduct for urging the jury to consider 404(b) evidence for an improper purpose.

Issue	Grier's Argument	State's Argument	Held
Sufficiency of the evidence	Evidence was inadequate to prove guilt beyond a reasonable doubt	Evidence (admission, cell data, eyewitness placement, firearm link) suffices	Affirmed: evidence sufficient to support convictions (Jackson standard)
Ineffective assistance — failure to object to lay witnesses' statements that Grier "did it"	Trial counsel should have objected because those comments invaded the jury's province on the ultimate issue	Lay opinions were rationally based on perception and admissible under OCGA §24‑7‑701; no deficient performance	Waived as to one witness; otherwise no deficient performance — counsel not ineffective
Ineffective assistance — failure to object to prosecutor's closing comment about Rule 404(b) evidence	Counsel should have objected to prosecutor treating prior‑acts evidence as character evidence	Jury had already heard 404(b) evidence, court instructed on limited use, and closing argument is not evidence; no prejudice shown	No prejudice; claim fails (no reasonable probability of different result)
Prosecutorial misconduct for urging impermissible consideration of 404(b) evidence	Prosecutor improperly asked jury to use other‑acts evidence to infer propensity and intent	No contemporaneous objection at trial; issue waived on appeal	Waived for failure to object contemporaneously; not reviewable

Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency‑of‑the‑evidence standard)
Rampley v. State, 235 Ga. 101 (confession corroboration supports conviction)
Worthem v. State, 270 Ga. 469 (confession corroboration and sufficiency)
Stuckey v. State, 301 Ga. 767 (Strickland standard applied in Georgia appellate review)
United States v. Campo, 840 F.3d 1249 (lay‑opinion testimony admissible when rationally based and helpful)
United States v. Dulcio, 441 F.3d 1269 (expert vs. lay limits on ultimate‑issue testimony)