Lanier v. State
288 Ga. 109
| Ga. | 2010Background
- Lanier was convicted of malice murder, armed robbery, and aggravated assault for the beating death of David Rigdon.
- Evidence linked Lanier to the crime: DNA on a shoe matched the victim; blood spatters on Lanier’s shoe; wallet recovered at a location they visited.
- Victim died from blunt-force head injuries likely inflicted with a hammer.
- Defendant cooperated minimally; Mikell identified the drive route and implicated Lanier.
- Trial court denied new-trial motion; Lanier appealed to Georgia Supreme Court; issues raised include evidence sufficiency, mistrial, ineffective assistance, and conflict of interest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the evidence legally sufficient to support guilt? | Lanier | State | Yes; evidence rationally supports verdict beyond a reasonable doubt. |
| Did the parole reference during cross-examination require mistrial? | Lanier | State | No; reference was nonprejudicial and not a character conditioning comment. |
| Was counsel ineffective for not pursuing independent DNA testing or lab review? | Lanier | State | No; no showing of deficient performance or probability of different outcome. |
| Was impeachment with a 1995 conviction properly denied for notice reasons? | Lanier | State | No reversible error; impeachment impact minimal given witness credibility issues. |
| Did trial counsel’s alleged conflict of interest affect the outcome? | Lanier | State | No; even if conflict existed, no demonstration it significantly affected performance. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency standard for federal review)
- Isaac v. State, 269 Ga. 875 (1998) (nonresponsive or minor parole references do not place character at issue)
- Walker v. State, 282 Ga. 703 (2007) (nonresponsive adverse effects on character are insufficient for mistrial)
- Junior v. State, 282 Ga. 689 (2007) (mistrial denial reviewed for abuse of discretion)
- Williams v. State, 284 Ga. 849 (2009) (tests for ineffective assistance based on expert testimony standards)
- Allen v. State, 286 Ga. 392 (2010) (impeachment value of prior convictions and notice requirements)
- White v. State, 287 Ga. 713 (2010) (conflict of interest considerations in Sixth Amendment context)