Griffin v. the State
331 Ga. App. 550
Ga. Ct. App.2015Background
- Griffin was convicted after a jury trial of cocaine trafficking and possession of marijuana with intent to distribute.
- A search of a Clayton County apartment on January 13, 2011 uncovered cocaine, marijuana, cash, scales, paraphernalia, and firearms; Griffin was among about ten people present.
- Griffin was found with cash and evidence suggesting involvement in drug distribution; a fellow codefendant testified Griffin funded purchases.
- The state introduced drug testing results showing cocaine under multiple purities and weights; a statement Griffin made about a separate incident was admitted.
- Griffin argued, among other things, that there was insufficient knowledge of the cocaine’s weight to sustain a trafficking conviction and challenged several trial-counsel decisions.
- The trial court’s weight-based sufficiency analysis and the effectiveness questions are central to this appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Griffin argues the state failed to prove knowledge of weight. | State contends the weight was established by circumstantial evidence. | Evidence sufficient under Jackson v. Virginia. |
| Ineffective assistance of counsel (a–f) | Griffin claims multiple trial-counsel failures prejudiced him. | State contends each claim lacks deficient performance or prejudice. | No deficient performance or prejudice shown; claims fail. |
| Judge’s comments on credibility | Griffin argues OCGA § 17-8-57 violation occurred via judge’s remarks. | State asserts remarks were brief and not prejudicial. | No violation; comments were permissible brief exchanges. |
| Admission of acquittals of codefendants | Griffin sought admission of codefendants’ acquittals. | State resisted; acquittals not essential to Griffin’s case. | Court did not abuse discretion; acquittals excluded. |
| Evidentiary rulings | Griffin challenges relevance rulings, including no-knock-warrant context and re-cross questions. | State argues rulings were within trial court’s broad discretion. | No reversible error; rulings within discretion. |
Key Cases Cited
- Taylor v. State, 272 Ga. 559 (2000) (invocation reference not per se reversible error)
- Morris v. State, 161 Ga. App. 141 (1982) (tagging evidence may be prejudicial when residence is at issue)
- Spence v. State, 96 Ga. App. 19 (1957) (arrest ticket may be prejudicial error)
- Jinks v. State, 229 Ga. App. 18 (1997) (unredacted documents can be reversible error)
- Brown v. State, 195 Ga. App. 389 (1990) (listing of defendant’s name does not automatically prejudice)
