Huntley v. State
331 Ga. App. 42
| Ga. Ct. App. | 2015Background
- Huntley was convicted after a jury trial of sale of cocaine, distributing cocaine near a school, and distributing cocaine near a park.
- Evidence showed Huntley drove Wheeler to two cocaine transactions on November 29, 2010, with a confidential informant nearby.
- The first sale occurred less than 1,000 feet from a park and a school; drugs were passed from Wheeler to the informant at Huntley’s car.
- Huntley then drove Wheeler to a second location where Wheeler again sold cocaine to the informant, after which Huntley drove away.
- Wheeler, not Huntley, directly sold to the informant, but the record supported Huntley as a party to the crimes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Huntley contends evidence fails to prove guilt beyond a reasonable doubt. | Huntley argues insufficient evidence to prove party to crimes. | Evidence 충분 to support verdict as party to crimes. |
| Directed verdict defense | Sufficiency claim should have led to directed verdict. | Failure to move for directed verdict amounted to ineffective assistance. | No error; meritless directed-verdict motion would not be ineffective assistance. |
| Videotape evidence | Videotapes should have been objected to. | Counsel strategy didn't require objection; tapes admissible. | Strategic decision not to object was permissible; not ineffective assistance. |
| Explanation of party-to-a-crime law | Counsel failed to explain party-to-a-crime law adequately. | Counsel thoroughly explained the concept; Huntley understood it. | Appellate due to factual findings supports trial court; no ineffective assistance. |
Key Cases Cited
- Stillwell v. State, 329 Ga. App. 108 (Ga. App. 2014) (evidence sufficiency standard; jury credibility; preserve verdicts)
- Burks v. State, 268 Ga. 504 (Ga. 1997) (party to crime concept; intent can be inferred)
- Buruca v. State, 278 Ga. App. 650 (Ga. App. 2006) (driver role can support party-to-crime conviction)
- Thornton v. State, 292 Ga. 87 (Ga. 2012) (driver of getaway vehicle as party to crimes)
- Wade v. State, 305 Ga. App. 819 (Ga. App. 2010) (driving to location supports party-to-crime conviction)
- Head v. State, 261 Ga. App. 185 (Ga. App. 2003) (supporting party-to-crime analysis)
- Hill v. State, 291 Ga. 160 (Ga. 2012) (ineffective assistance standard; performance and prejudice required)
- Hendrix v. State, 328 Ga. App. 819 (Ga. App. 2014) (trial strategy considerations in evaluating objections)
- Sowell v. State, 327 Ga. App. 532 (Ga. App. 2014) (trial strategy and effective assistance considerations)
- Grier v. State, 273 Ga. 363 (Ga. 2001) (tactical trial decisions not always error)