Keener v. State, 301 Ga. 848

Keener was tried in two separate trials for different victims, Yearwood (Counts 7–9) and Huling (Counts 1–4).
Yearwood was beaten at a homeless encampment; Yearwood’s ear was injured and later sewn up; Keener testified in his own defense claiming self-defense.
Huling was assaulted near a liquor store; witnesses described a head slam into a guardrail; Huling died from blunt force trauma.
A medical examiner linked Huling’s death to a guardrail impact, while a defense forensic pathologist attributed it to a fall causing a head injury.
During pretrial detention, Keener allegedly admitted to smashing Huling’s head into a guardrail; Charlie testified in various regards about the event.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Impeachment with prior statements	Keener contends Charlie’s inconsistent statements should have been used to impeach him.	State argues trial counsel’s impeachment strategy was reasonable given the muddled interview and defense theory.	No deficient performance; cross-examination was appropriate and strategy not patently unreasonable.
Weight of the evidence standard for new trial	Keener claims the court applied the wrong standard when denying the new-trial motion.	State argues the court properly weighed the evidence and exercised its discretion.	Court did not err; the trial court fulfilled its duty to weigh the evidence.
Sufficiency of the evidence	Keener asserts the evidence was legally insufficient to sustain the convictions.	State maintains the record robustly supports guilt beyond a reasonable doubt.	Evidence was sufficient to support the convictions.

Strickland v. Washington, 466 U. S. 668 (U.S. Supreme Court (1984)) (standard for ineffective assistance of counsel)
Harrington v. Richter, 562 U. S. 86 (U.S. Supreme Court (2011)) (gives framework for evaluating trial counsel performance with deference)
Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court (1979)) (sufficiency of evidence standard for criminal convictions)
Romer v. State, 293 Ga. 339 (Ga. 2013) (objective standard for prejudice in ineffective assistance claims)
Shaw v. State, 292 Ga. 871 (Ga. 2013) (hindsight not allowed in evaluating counsel performance)
Arnold v. State, 292 Ga. 268 (Ga. 2013) (objective standard for deficient performance and prejudice)
Brown v. State, 288 Ga. 902 (Ga. 2011) (counsel’s tactical decisions reviewed under Strickland)
Walker v. State, 292 Ga. 262 (Ga. 2013) (trial court’s discretion in new-trial motions)
Rector v. State, 285 Ga. 714 (Ga. 2009) (discretionary review of weight-of-the-evidence claims)