Humphrey v. Williams, 295 Ga. 536

Williams was convicted in 2002 of child molestation and related offenses stemming from alleged 2000 acts with his stepdaughter and her friend; Florida records suggested a 1993 incident involving Jessica, which could be probative of Williams's pattern and motive.
Grantham, Williams’s trial counsel, failed to obtain Florida court records pertinent to the 1993 alleged incident.
Florida records were later admitted at a 2008 habeas hearing, showing prior findings that undermined Jessica’s 1993 claims.
Habeas court set aside Williams’s convictions in 2012 on ineffective assistance grounds, holding Grantham’s investigation deficient and that Florida records would have precluded or impeached similar-transaction evidence.
State appealed, arguing the Florida records were never admitted in habeas proceedings and that no prejudice occurred; the Georgia Supreme Court affirmed the habeas order.
Court allowed retrial if the State chose to retry, having found significant prejudice from trial counsel’s deficient performance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Grantham’s failure to obtain Florida records was deficient performance.	Williams (habeas) contends records would have changed trial.	Warden argues no admissible Florida records and no prejudice.	Yes; deficient performance established.
Whether Florida records admitted at habeas hearing would have barred similar-transaction testimony.	Records would preclude or impeach Jessica’s 1993 testimony.	Collateral estoppel could apply only with acquittal; no acquittal here.	Records would have precluded/adversely affected similar-transaction evidence.
Whether prejudice flowed from the similar-transaction testimony despite other evidence of guilt.	Prejudice from unreliable similar-transaction testimony affected outcome.	Evidence of guilt was overwhelming beyond the similar act.	There is reasonable probability the result would be different with proper impeachment/exclusion.
Whether collateral estoppel or related doctrines foreclose use of similar-transaction evidence.	Moore collateral estoppel would preclude admission.	No prior acquittal; dual sovereignty precedent applies.	Collateral estoppel not binding; Florida records still prejudiced trial.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes standard for ineffective assistance of counsel)
Rompilla v. Beard, 545 U.S. 374 (U.S. 2005) (deficient investigation of readily available court file)
Moore v. State, 254 Ga. 674 (Ga. 1985) (collateral estoppel excludes similar transaction evidence upon acquittal findings)
Dowling v. United States, 493 U.S. 342 (U.S. 1990) (dual sovereign doctrine; collateral estoppel does not bar later prosecution by another sovereign)
Heath v. Alabama, 474 U.S. 82 (U.S. 1985) (dual sovereignty; successive prosecutions not barred by double jeopardy)
Head v. Taylor, 273 Ga. 69 (Ga. 2000) (readily available jail records as part of defense investigation)
Salcedo v. State, 258 Ga. 870 (Ga. 1989) (application of collateral estoppel to prior Florida-related evidence)