Jackson v. State, 309 Ga. App. 450

Jackson was convicted of two counts of aggravated child molestation and one count of child molestation; sentenced to life without parole; appealing denial of motion for new trial.
Victim G.W. lived with Jackson for several years, described a routine of sexual abuse including anal penetration and oral sex.
Similar-transaction evidence involved a 1989 case where Jackson pled guilty to aggravated child molestation of an eight-year-old and was mentally ill.
State sought to admit the prior acts for purposes including identity, plan, motive, bent of mind, and course of conduct; trial court admitted for bent of mind, course of conduct, and lustful disposition.
Prosecutor argued about the victim’s veracity using detailed testimony; defense contends this created error and ineffective assistance claim.
Court affirmed: evidence admissible for lustful disposition and course of conduct; no ineffective assistance based on closing argument remarks.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of similar-transaction evidence	Jackson	Jackson	Admissible for lustful disposition and course of conduct.
Ineffective assistance claim based on closing arguments	Jackson	Jackson	No error; arguments did not express prosecutor’s personal belief; objections meritless.

Woods v. State, 304 Ga.App. 403 (2010) (admissibility of similar-transaction evidence in sexual abuse cases; relevance balances prejudice)
Pareja v. State, 286 Ga. 117 (2009) (requirements for admissibility of similar transactions; relevance and similarity)
Cook v. State, 276 Ga.App. 803 (2005) (lustful disposition evidence in child molestation cases)
Jackson v. State, 443 U.S. 307 (1979) (standard for determining sufficiency of evidence (App. review))
Moody v. State, 273 Ga. 24 (2000) (proper framing of closing argument issues on appeals)
Williams v. State, 263 Ga.App. 22 (2003) (contextual detail and witness credibility arguments)