Keaton v. State, 318 Ga. App. 446

Keaton was convicted after a jury trial of burglary and possession of tools for crime; sentenced to 20 years.
Keaton filed a motion for new trial which the trial court denied after a hearing.
Appellate review affirms the conviction and denial of the new trial motion.
Appellant contends trial counsel provided ineffective assistance.
Key issue is whether failure to suppress statements tainted the verdict and whether suppression would have changed the outcome.
The stop and custodial interrogation involved inconsistent statements by Keaton and initial Miranda handling at the scene.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance standard dispute	Keaton argues deficient performance affected outcome	Keaton asserts trial counsel failed to raise suppression issue	No reversible error; no showing of prejudice found
Failure to move to suppress statements	Keaton claims suppression would help	Counsel chose strategy; statements corroborated defense	Trial counsel's non-motion not ineffective; no proven likelihood of suppression changing outcome
Suppression would have changed outcome	Potential suppression would undermine state's case	Insufficient showing to prove would have been granted	Keaton failed to show suppression would have been granted; no merit to ineffective claim

Rivers v. State, 283 Ga. 1 (2008) (strong showing required to prove suppressive error at trial)
Edenfield v. State, 238 Ga. App. 362 (1999) (trial court findings affirmed absent clear error; no ineffective assistance shown)
Robinson v. State, 277 Ga. 75 (2003) (independent application of legal principles to facts; standard of review for ineffective assistance)
Ledford v. State, 313 Ga. App. 389 (2011) (may forgo addressing both prongs if one is unmet; harmless error standard)
Ellis v. State, 282 Ga. App. 17 (2006) (standard for appellate review of evidence in light most favorable to verdict)