Hood v. State, 308 Ga. 784

On Feb. 17, 2015, Candace McGriff was found fatally shot in her apartment; Antione Hood was the only other person present and told neighbors she had shot herself.
A 9mm Ruger recovered from the scene fired the fatal bullet; a nurse saw the gun on the bed near McGriff’s body.
Scene and autopsy investigators found no visible gunshot powder residue (GPR) or stippling on McGriff’s hands, chest wound, or loose-weave sweater; distance testing by the State’s investigator showed GPR/stippling at up to about 24 inches but not beyond.
GBI microscopic testing of swabs from Hood’s hands detected three particles characteristic of gunshot primer residue (GSR), which could indicate firing, close proximity to a discharged firearm, or transfer contact.
Hood was indicted and convicted of felony murder (predicated on aggravated assault) and possession of a firearm during the commission of a felony; he received life without parole plus five years.
Hood claimed trial counsel was ineffective for failing to consult/call a GSR/GPR expert (Christopher Robinson); at a new-trial hearing Robinson testified about potential GPR trapped in the sweater and criticized the GBI policy on victim GSR testing. The trial court and this Court held Hood failed to show Strickland prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for failing to consult/call GSR/GPR expert	Hood: counsel’s failure to consult Robinson deprived jury of evidence that could support a self-inflicted theory (e.g., microscopic/chemical testing of sweater; GSR interpretation)	State: counsel made a reasonable strategic choice, had another consultant, Robinson’s points were speculative or consistent with State experts, and would not likely change outcome	Denied — even assuming deficiency, Hood failed to show a reasonable probability of a different result under Strickland (no prejudice)
Sufficiency of the evidence	Hood did not contest sufficiency	State: evidence (scene, autopsy, distance testing, GSR on Hood’s hands, witness statements) supports convictions	Affirmed — evidence sufficient to support convictions under Jackson v. Virginia

Jackson v. Virginia, 443 U.S. 307 (establishes standard for reviewing sufficiency of the evidence)
Strickland v. Washington, 466 U.S. 668 (establishes two-prong test for ineffective assistance of counsel)
Romer v. State, 293 Ga. 339 (Georgia discussion of objective-reasonableness in counsel performance)
Jowers v. State, 260 Ga. 459 (example of successful ineffective-assistance claim based on failure to investigate/present key scientific evidence)
Matthews v. State, 301 Ga. 286 (expert testimony at a new-trial hearing must rebut State experts to show prejudice)
Gomez v. State, 301 Ga. 445 (no prejudice when new experts’ equivocal testimony would not have likely changed outcome)
Parker v. State, 305 Ga. 136 (mere speculation about what evidence might have shown is insufficient to prove prejudice)
Howard v. State, 298 Ga. 396 (similar holding on speculative evidence and prejudice)
Richardson-Bethea v. State, 301 Ga. 859 (clarifies the reasonable-probability standard for withheld evidence)
Wesley v. State, 286 Ga. 355 (Georgia application of Strickland standard)
Lawrence v. State, 286 Ga. 533 (court may dispose of ineffective-assistance claim by addressing only one Strickland prong)