Jeffers v. State, 290 Ga. 311

Jeffers was convicted of malice murder, felony murder, aggravated assault, aggravated battery, and weapon offenses for the stabbing death of Williams and assault of Stringfellow; sentence included life imprisonment and consecutive terms.
Video surveillance captured the entire attack; Jeffers followed Williams back to the restaurant, left, circled the building, then reentered with a knife and fatally stabbed Williams.
Evidence showed the victim Williams sought shelter from Jeffers, who previously followed her; Stringfellow aided, and other employees restrained Jeffers until police arrived.
Jeffers challenged several evidentiary rulings and raised ineffective assistance of trial counsel on appeal; the court reviewed the record de novo for sufficiency and preservation.
Close to trial, several hearsay and character-evidence issues arose under OCGA 24-3-1 and related rules, including necessity exceptions and curative instructions.
The court addressed preserving errors, contemporaneous objections, and the duty to voir dire or renew objections to preserve appellate review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Jeffers argues evidence insufficient for guilt beyond reasonable doubt.	State contends sufficient evidence supports convictions and rejects insanity defense.	Evidence sufficient to sustain guilty verdicts beyond reasonable doubt.
Closing argument about obscene gesture	Jeffers claims remark was improper and harmful, impugning character.	State contends no preservation; comment within permissible courtroom demeanor; regularity presumed.	No reversible error; trial court properly discharged duties; argument permissible.
Ineffective assistance for failure to object	Failure to object to improper closing argument constituted deficient performance and prejudice.	Even if objected, prejudice unlikely where evidence is overwhelming.	Strickland prejudice not shown; no reversal for ineffective assistance.
Admission of hearsay under necessity exception	Statements lacked particularized guarantees of trustworthiness; improper under necessity.	Necessity satisfied by unavailable declarant and confidential relationships; trustworthiness established.	Court did not abuse discretion; hearsay admitted under necessity exception.
Curative instruction on stalking reference	Trial court should have given curative instruction to address reference to stalking.	Court offered instruction; defense declined; waived error by counsel's decision.	No error; curative instruction not required when defense declined and delay bar cures not needed.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for guilt beyond reasonable doubt)
Westmoreland v. State, 287 Ga. 688 (2010) (presumption of regularity; required preservation of error for appeal)
Hardnett v. State, 285 Ga. 470 (2009) (prosecutor may comment on defendant’s courtroom demeanor)
Higuera-Hernandez v. State, 289 Ga. 553 (2011) (preservation and appropriate grounds for errors in appeals)
Tuff v. State, 278 Ga. 91 (2004) (necessity and trustworthiness in admitting hearsay under OCGA 24-3-1)
Pickren v. State, 272 Ga. 421 (2000) (curative instruction and timing in curtailing prejudicial references)
Crawford v. Washington, 541 U.S. 36 (2004) (confrontation clause; non-testimonial statements context noted)