Handley v. State, 289 Ga. 786

A jury convicted Handley of malice murder of William Stillwell and felony weapons possession; sentences were life for murder and five years consecutively for the weapon offense.
The victim stopped to buy crack cocaine; Handley and several men surrounded the victim’s vehicle during the dispute.
Handley allegedly snatched the victim’s keys, produced a handgun, and shot the victim in the chest; the group fled the scene.
The State’s witnesses included some who were suspects or testified under immunity; no forensic evidence tied Handley to the shooting.
The defense challenged the sufficiency of evidence and credibility of eyewitnesses; however, the jury weighed credibility and resolved conflicts.
On appeal, Handley raised issues regarding ineffective assistance of counsel and trial strategy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for murder	Handley contends no forensic or physical proof placed him at the scene or proven culpability.	Eyewitness testimony alone can sustain a murder verdict; credibility issues go to the jury.	Evidence sufficient; jury could rationally convict
Ineffective assistance—bolstering on direct exam	Counsel failed to object to bolstering testimony by a witness about telling the truth.	Strategic decision to permit the witness to speak to truthfulness, later impeached by prior statements.	No reversal; strategy reasonable and supported by record
Ineffective assistance—mug shot identification testimony	Counsel should have objected to officer referencing Handley’s photo during lineup.	References were a minor, non-prejudicial part of normal police procedure.	No reversal; not a ground for ineffective assistance
Ineffective assistance—conflict of interest in counsel’s redirect	Counsel’s redirect implied conflict; trial relied on her reputation and priorities over defendant.	There was no actual conflict adversely affecting performance; testimony served to remind preparation.	No actual conflict; performance not ineffective

Colzie v. State, 289 Ga. 120 (2011) (one witness may suffice if credible to sustain conviction)
Reeves v. State, 288 Ga. 545 (2011) (single witness sufficiency in felony cases with credibility resolved by jury)
Herbert v. State, 288 Ga. 843 (2011) (accomplice testimony and corroboration rules in jury credibility)
Kinney v. State, 271 Ga. 877 (2000) (jury resolve credibility; accomplice testimony permissible for corroboration)
Rucker v. State, 272 Ga. 750 (2000) (pretrial statements and credibility addressed by jury)
Sharpe v. State, 272 Ga. 684 (2000) (jury may credit impeaching statements over exculpatory testimony)
Harden v. State, 278 Ga. 40 (2004) (course of credibility assessment where witnesses’ demeanor matters)
Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency of evidence standard for ruling on criminal conviction)
Moore v. State, 288 Ga. 187 (2010) (accomplice relationship and credibility considerations)
Suggs v. State, 272 Ga. 85 (2000) (standard of review in ineffective assistance claims)
Lindo v. State, 278 Ga. App. 228 (2006) (counsel's strategy and conflicts in defense practices)
Gregoire v. State, 309 Ga. App. 309 (2011) (fact-intensive review of trial counsel decisions)
White v. State, 267 Ga. 523 (1997) (reference to mug shots within permissible context)
Pullen v. State, 208 Ga. App. 581 (1993) (conflicts of interest and governance of defense strategy)