Hargrove v. State, 291 Ga. 879

Appellant Bruce Wayne Hargrove was convicted of malice murder for the January 7, 1999 shooting of Antonio Jamel Jordan in Baldwin County and was sentenced to life imprisonment.
Post-trial motions: motion for new trial denied; appellate review asserted ineffective assistance, insufficient evidence, venue defects, and due process delay from a 12-year gap.
Evidence: victim, a confidential informant, made a controlled cocaine buy from Hargrove; police arrested him for possession with intent to distribute; he later pled guilty in federal court.
Hargrove allegedly told witnesses he knew the snitch and sought revenge; he and others found the victim, bought marijuana, and then shot him at a remote dumpster site; body found next day.
The trial court allowed the jury to view the evidence as sufficient for conviction under Jackson v. Virginia; various evidentiary and evidentiary-claim challenges on appeal were addressed and rejected.
Court affirmed judgment, applying Strickland for ineffective assistance, addressing multiple sub-claims, evidentiary rulings, venue, and due process-delay analysis under Barker factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	State argues evidence supported conviction beyond reasonable doubt.	Hargrove contends evidence insufficient to prove malice murder.	Evidence sufficient under Jackson v. Virginia.
Ineffective assistance of counsel	State asserts trial counsel's performance was reasonable under Strickland.	Hargrove claims multiple deficient acts by counsel violated Strickland.	No reversible ineffective assistance; claims lack merit.
Prosecutor's inflammatory remarks and closing	State contends remarks were within proper rhetoric and strategy.	Hargrove argues remarks improperly placed his character in issue and were prejudicial.	Various remarks waived or not reversible; no merit in ensuing challenges.
Venue and jurisdiction	State asserts venue proven by testimony and statutory rules.	Hargrove challenges venue evidence as insufficient.	Venue properly established; count valid under OCGA 17-2-2(c).
Due process delay	State argues delay due to appellant's prior counsel, not State fault.	Hargrove asserts 12-year delay violates due process under Barker factors.	Delay not due to State; no demonstrated prejudice; no due process violation.

Jackson v. Virginia, 443 U.S. 307 (U.S. (1979)) (sufficiency standard for criminal proof; rational finder of fact)
Strickland v. Washington, 466 U.S. 668 (U.S. (1984)) (ineffective assistance standard; deficient performance and prejudice tests)
Kirkland v. State, 274 Ga. 778 (Ga. 2002) (challenge for cause; juror bias; discretionary ruling)
Cade v. State, 289 Ga. 805 (Ga. 2011) (juror bias and voir dire; deference to trial court)
Higginbotham v. State, 287 Ga. 187 (Ga. 2010) (defining bias; cause challenges based on opinions)
Bradfield v. State, 262 Ga. 786 (Ga. 1993) (sheriff's office relationships; per se disqualification limits)
Scott v. State, 227 Ga. App. 900 (Ga. App. 1997) (scope of closing argument; inappropriate remarks)
Mullins v. State, 270 Ga. 450 (Ga. 1999) (contemporaneous objection requirement; waiver)
Watson v. State, 278 Ga. 763 (Ga. 2004) (curative instructions and waiver of error)
Chatman v. Mandil, 280 Ga. 253 (Ga. 2006) (Barker-based speedy-trial framework applied to delays in appeal)