Lacey v. State, 288 Ga. 341

Lacey was convicted after a jury trial of malice murder, two counts of felony murder, armed robbery, two counts of aggravated assault, and firearm possession during a crime connected to Cunningham's death and Mayhew's injury.
Cunningham planned to sell marijuana; Mayhew and Freeman were present on the porch when Lacey arrived with Buskey and went inside to retrieve a scale.
A struggle and gunfire occurred; Mayhew was shot while Cunningham later died from a gunshot wound to the abdomen.
Buskey testified about Dyer’s plan to rob Cunningham; she drove Lacey to Cunningham’s home and described related statements by Dyer, Chapman, Torres, and Crossley.
Dyer, Torres, Chapman, and Crossley provided testimony about Lacey’s version of events, including fights, a gun fall, and Lacey firing three times.
The trial court denied new-trial relief; on appeal, Lacey challenged jury instructions, prosecutorial conduct, and ineffective assistance of counsel claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Lacey argues insufficient evidence to convict.	State asserts sufficient evidence supports guilt.	Evidence sufficient beyond reasonable doubt
Failure to give party to a crime/conspiracy charges	Requested charges necessary to address witness bias and biasing context.	Waived due to lack of timely specific objection; plain error absent.	Waiver without plain error; no reversible error
Prosecutorial comments on right to silence and victim impact	Prosecutor improperly commented on silence and used impermissible victim-impact argument.	Remarks were proper context and not aimed at denial of testimony.	Waived and not reversible error
Ineffective assistance of counsel	Counsel failed to object to improper prosecutorial conduct.	No deficient performance or prejudice shown; remarks not improper.	No ineffective assistance established
Specifics of trial objections/waiver	Trial objections preserved certain issues for appellate review.	Defaulted objections; plain error not shown.	Procedural waiver without plain error

Jackson v. Virginia, 443 U.S. 307 (1980) (standard for reviewing sufficiency of evidence)
Smith v. State, 279 Ga. 48 (2005) (prosecutor may not comment on failure to testify)
Sampson v. State, 282 Ga. 82 (2007) (waiver of objections to prosecutorial conduct)
Braithwaite v. State, 275 Ga. 884 (2002) (waiver of objections to prosecutorial conduct)
Lampley v. State, 284 Ga. 37 (2008) (standard for ineffective assistance claims)
Sermons v. State, 262 Ga. 286 (1992) (incidental victim-impact context in guilt phase)
Thornton v. State, 264 Ga. 563 (1994) (legality of references to victim status in non-death context)
Brown v. State, 258 Ga. App. 78 (2002) (admission of victim-related evidence for proper purpose)