Inman v. State, 294 Ga. 650

Appellant Kenneth Inman was convicted of murder, kidnapping with bodily injury, and related offenses for crimes against Tedder and Niebaum.
The incidents occurred June 15, 2005, at Inman's house where he confronted Tedder and Niebaum over allegedly stolen marijuana.
Inman brandished a shotgun and pistol, moved the victims to the back yard, and after shootings dragged them behind a shed; Tedder died on scene.
The State introduced evidence of movement of the victims, which the court evaluated under Garza v. State to sustain kidnapping convictions.
A pretrial immunity defense based on defense of habitation was denied; conflicting testimony about entries and threats affected the immunity ruling.
Appellant asserted ineffective assistance of trial counsel related to handling of an investigator (Shouse) and other trial decisions; the trial court denied post-trial motions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of kidnapping evidence	Inman contends Garza factors negate asportation evidence.	State argues Garza factors support non-trivial movement increasing danger.	Sufficient evidence under Garza to sustain kidnapping convictions.
Prosecutorial misconduct from Shouse disclosures	Inman claims ADA had improper inside information from Shouse affecting case.	State argues no prejudice since information not used and agreement not to call Shouse was honored.	No merit; no prejudice established.
Ineffective assistance regarding Shouse and disclosures	Counsel failed to protect privilege and manage disclosures prejudicially.	No prejudice shown; preparation was extensive and disclosures not shown to affect outcome.	No prejudice; ineffective-assistance claim fails.
Defense-of-habitation immunity	Evidence supports defense where deadly force used to defend habitation.	Evidence shows entry not violent/forbidden and no felony attempted, undermining immunity.	Immunity denied; evidence supports trial court ruling.
jury instruction on self-defense and voluntary manslaughter (plain error)	Re-charge misled jury into requirement of murder verdict if interval existed, negating self-defense.	Overall charge properly instructed on self-defense interaction; no plain error.	No plain error; instructions considered as a whole were correct.

Garza v. State, 284 Ga. 696 (2008) (four-factor framework for kidnapping asportation)
Thomas v. State, 289 Ga. 877 (2011) (Garza factors applied as a whole need not all be met)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of evidence)
Vega v. State, 285 Ga. 32 (2009) (reliability of jury credibility in verdicts)
Williams v. State, 291 Ga. 501 (2012) (additional danger from victim movement supports kidnapping)
Sifuentes v. State, 293 Ga. 441 (2013) (standard for reviewing conflicting trial testimony)
Johnson v. State, 258 Ga. 856 (1989) (prosecutorial misconduct claim analysis)