Jones v. State, 288 Ga. 431

Jones was convicted of malice murder and a firearm offense for the fatal shooting of his common-law wife in October 1995, and this Court had previously affirmed but remanded for an evidentiary hearing on ineffective-assistance claims raised on direct appeal.
Evidence showed the shotgun fired at close range, with victim found dead and forensic results indicating the muzzle was near her mouth and gunpowder residue on her, corroborating a close-quarters firing.
Jones gave multiple inconsistent statements about the shooting and thereafter attempted to minimize his involvement, including telling a jailmate various versions and cleaning himself to remove gunpowder residue.
The State argued during closing that Jones could be a future danger if acquitted, and Jones contends counsel was ineffective for not objecting to this improper argument.
The trial court denied a new trial based on ineffective assistance, and the Georgia Supreme Court affirmed, applying Strickland and evaluating prejudice separately.
The Court held that there was overwhelming evidence of guilt and that no reasonable probability existed that a failure to object would have changed the outcome.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for failing to object to prosecutorial argument.	Jones asserts failure to object was deficient performance.	Jones contends the argument improperly suggested future dangerousness and prejudiced the trial.	No prejudice; evidence overwhelming, so outcome would not differ.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective-assistance standard)
Fulton v. State, 278 Ga. 58 (Ga. 2004) (improper argument may be deficient but not necessarily prejudicial)
Wallace v. State, 272 Ga. 501 (Ga. 2000) (prosecutorial misstatement and prejudice standards)
Bell v. State, 287 Ga. 670 (Ga. 2010) (prejudice required if deficient performance shown)
Lambert v. State, 287 Ga. 774 (Ga. 2010) (preserving prejudice inquiry when trial strategy is argued)
Futch v. State, 286 Ga. 378 (Ga. 2010) (ineffective assistance standard and prejudice analysis)