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Henry v. State
297 Ga. 74
| Ga. | 2015
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Background

  • Henry was convicted of malice murder, burglary, and unlawful possession of a firearm in the August 9, 2010 shooting of John Golden.
  • Cassandra Reynolds bought an AK-47 for Henry and kept it in her home; Henry broke into her house to obtain the gun.
  • Henry fired the AK-47 on Golden’s porch, killing him, after being seen threatening others and boasting of the loaded weapon.
  • Henry told a friend he had shot someone and disposed of ammunition nearby; the State presented evidence of the weapon and related conduct.
  • Henry challenged the sufficiency of the evidence and claimed ineffective assistance of counsel; the trial court denied post-trial relief, and the Supreme Court of Georgia affirmed.
  • The court applied Jackson v. Virginia clear-error-free standard for sufficiency and Strickland for ineffective assistance, evaluating trial counsel’s performance and prejudice.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of the evidence Henry argues the evidence is legally insufficient for malice murder. State contends the evidence supports a rational jury’s guilt beyond reasonable doubt. Evidence legally sufficient to support conviction.
Effectiveness of counsel - overall Henry claims trial counsel failed to provide effective representation in multiple respects. State asserts counsel’s performance was reasonable and not prejudicial. Henry failsto show deficient performance or prejudice.
Counsel communication and investigation failures Henry contends counsel did not adequately consult or investigate the case. State argues communications and investigations were reasonable and not prejudicial. No deficient performance shown; no prejudice demonstrated.

Key Cases Cited

  • Walker v. State, 296 Ga. 161 (Ga. 2014) (sufficiency standard; avoid weighing credibility)
  • Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review; rational juror)
  • Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective assistance standard; performance and prejudice)
  • Kimmelman v. Morrison, 477 U.S. 365 (U.S. 1986) (ineffective assistance scope; trial conduct)
  • Lowe v. State, 295 Ga. 623 (Ga. 2014) (no fixed required conference time; uncooperative client)
  • Glass v. State, 289 Ga. 542 (Ga. 2011) (communication with counsel; evidentiary considerations)
  • Williams v. State, 281 Ga. 196 (Ga. 2006) (counsel discuss charges and alibi; strategic decisions)
  • Browder v. State, 294 Ga. 188 (Ga. 2013) (new trial standard; review of trial counsel)
  • Arthur v. Walker, 285 Ga. 578 (Ga. 2009) (slip of the tongue not reversible error)
  • Davis v. State, 329 Ga. App. 797 (Ga. App. 2014) (record demonstrates trial counsel’s actions; prejudice require)
  • Rodriguez v. State, 211 Ga. App. 256 (Ga. App. 1993) (cross-examination and credibility considerations)
  • Bass v. State, 208 Ga. App. 859 (Ga. App. 1993) (burden shifting; trial court rulings)
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Case Details

Case Name: Henry v. State
Court Name: Supreme Court of Georgia
Date Published: May 11, 2015
Citation: 297 Ga. 74
Docket Number: S15A0189
Court Abbreviation: Ga.