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Lamar v. State
297 Ga. 89
| Ga. | 2015
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Background

  • Lamar was convicted after a jury trial of murder, felony murder, aggravated assault, and firearm charges related to McCrae's death and a separate aggravated assault on Williams.
  • A man matching Lamar's description shot McCrae at a barbecue; a week later witnesses placed Lamar at the scene or involved in the events with a backpack.
  • Ballistic testing tied the gun Lamar held during the Williams confrontation to the murder weapon.
  • Two prior similar transactions were admitted: a 1998 school-shooting incident and a 2009 incident involving a false name arrest, used to show course of conduct and intent.
  • Lamar challenged ineffective assistance of counsel for failing to object to several prosecutor comments; the trial court and appellate court denied relief.
  • The Georgia Supreme Court affirmed, holding the evidence sufficient and the trial court proper in admitting similar transactions and in rejecting ineffective assistance challenges.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of the evidence Lamar argues Stallings killed McCrae; insufficient evidence against him. Jury properly credited evidence linking Lamar to the murder beyond reasonable doubt. Evidence sufficient to sustain the verdict.
Admission of similar transactions Similar-transaction evidence was improper and prejudicial. Evidence admissible for course of conduct, intent, and lack of mistake; sufficient similarity. Court did not abuse discretion; admissions affirmed.
Ineffective assistance of counsel Counsel failed to object to several prosecutorial comments; prejudicial error. No deficient performance or prejudice; substantial evidence of guilt supports correctness. No ineffective assistance; judgment affirmed.
Prosecutorial comments and closing arguments Prosecutor's comments improperly bolstered witness credibility and misstated law. Any comments were within wide latitude of closing arguments and harmless given evidence. No reversible error; arguments proper or harmless.

Key Cases Cited

  • Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency standard requires proof beyond reasonable doubt)
  • Hall v. State, 264 Ga. 85 (1994) (credibility determinations reside with jury)
  • Matthews v. State, 294 Ga. 50 (2013) (admissibility of similar transactions for appropriate purposes)
  • Reed v. State, 291 Ga. 10 (2012) (abuse of discretion standard for admission of evidence)
  • Bell v. State, 294 Ga. 443 (2014) (ineffective assistance standard; prejudice required)
  • Conner v. State, 251 Ga. 113 (1983) (closing argument latitude)
  • Scott v. State, 290 Ga. 883 (2012) (closing argument reasonable inferences from evidence)
  • Varner v. State, 285 Ga. 300 (2009) (wide leeway in closing argument)
  • Fordham v. State, 254 Ga. 59 (1985) (witness may not give ultimate-issue opinion)
  • Wright v. State, 291 Ga. 869 (2012) (standards for ineffective assistance, procedural posture)
  • Strickland v. Washington, 466 U.S. 668 (1984) (two-pronged test for ineffective assistance)
  • Fuller v. State, 277 Ga. 505 (2004) (application of Strickland in state cases)
  • Brown v. State, 295 Ga. 804 (2014) (similar-act analysis and evidentiary discretion)
Read the full case

Case Details

Case Name: Lamar v. State
Court Name: Supreme Court of Georgia
Date Published: May 11, 2015
Citation: 297 Ga. 89
Docket Number: S15A0341
Court Abbreviation: Ga.