Lane v. State, 299 Ga. 791

Dye was shot by Lane, a neighbor, at about 4:40 a.m. on October 8, 2010; Dye exclaimed that Lane shot him.
Grier and Neely testified seeing or hearing Dye say he was shot by his neighbor; 911 was called by Grier.
Law enforcement searched Lane’s apartment and found cocaine and packaging materials in a cigar box; Lane’s sister stated Lane sold crack cocaine.
Lane testified at trial claiming the shooting was accidental and that he did not know anyone was hit.
A criminal trial was held December 6-8, 2011; Lane sought continuances and new counsel due to alleged communication and preparation issues.
Lane criticized his trial counsel for alleged lack of preparation and sought to impeach a key witness with prior felonies; the trial court denied continuances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Lane argues the evidence did not prove malice murder beyond reasonable doubt.	State contends the eyewitness testimony and Dye’s statements support malice murder.	Evidence supported conviction beyond reasonable doubt.
Denial of continuance to allow new counsel	Lane needed time for new counsel to prepare and investigate accident defense.	Court acted within its discretion; Lane failed to cooperate; speedy-trial rights previously asserted were withdrawn.	No abuse of discretion; continuance properly denied.
Effectiveness of trial counsel—general performance	Counsel failed to adequately prepare and failed to impeach a key witness; performance deficient.	Defense showed no prejudice; no post-trial basis to overturn trial given other evidence.	No ineffective assistance shown; performance reasonable; no prejudicial impact.
Effectiveness of trial counsel—impeachment of Williams	Counsel should have impeached Williams with prior felonies to undermine credibility.	Limited evidence of Williams's felonies; impeachment strategy was reasonable.	No reasonable probability of different outcome; no prejudice shown.

Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (standard for sufficiency of the evidence)
Davis v. State, 295 Ga. 168 (Ga. 2014) (continuance denial not reversible absent abuse of discretion)
Rivers v. State, 250 Ga. 303 (Ga. 1982) (no abuse of discretion when defendant refused to cooperate)
Smith v. Francis, 253 Ga. 782 (Ga. 1985) (ineffective assistance standard; two-prong test)
Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (standard for ineffective assistance of counsel)
Robinson v. State, 277 Ga. 75 (Ga. 2003) (independent application of law to facts; credibility determinations)
White v. State, 281 Ga. 276 (Ga. 2006) (presumption of reasonable performance; difficulty overcoming)
Peterson v. State, 284 Ga. 275 (Ga. 2008) (immediate post-trial considerations of counsel performance)
Sims v. State, 278 Ga. 587 (Ga. 2004) (evidence and trial conduct considerations in evaluating performance)
Williams v. State, 292 Ga. 844 (Ga. 2013) (impeachment and prejudice assessment standard)
Sanders v. State, 290 Ga. 637 (Ga. 2012) (limits on trial strategy impact on outcome)
Malcolm v. State, 263 Ga. 369 (Ga. 1993) (recidivist sentencing considerations)