Lawson v. State
296 Ga. 1
Ga.2014Background
- Herman Lawson and Christopher James were jointly indicted with two others for the August 20, 2005 murders of Jeremiah Ingram and Fatima Fisher; both were convicted of all charges including malice murder.
- Evidence tied the killings to a dispute over drugs at co-indictee Bruce Roberts’s apartment, where the victims were found by the group that included the co-indictees.
- Lawson and James were each sentenced to life for the murders; other charges merged; they were granted new trials which this Court later reversed, and their sentences were reinstated on remand.
- The State’s key witness was Karryngton Sims; other witnesses testified about timing and events; bodies were discovered around 8:30 a.m.; Bruce Roberts was acquitted at trial.
- On appeal, defendants argued ineffective assistance for failing to object to incomplete medical examiner summaries and failing to interview Hood; the court rejected these claims and affirmed judgments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Evidentiary sufficiency | Lawson | James | Sufficient evidence to convict |
| Incomplete autopsy summaries and prejudice | Lawson | James | No prejudice shown; no ineffective assistance |
| Failure to interview Hood as witness | Lawson | James | Trial strategy supported; no ineffective assistance |
| Due process and credibility of Sims | Lawson | James | No due process violation; inconsistencies not material |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (establishes two-prong Strickland standard for ineffective assistance of counsel)
- Bell v. State, 294 Ga. 443 (Ga. 2014) (deficient performance must be shown with prejudice to prevail)
- Johnson v. State, 295 Ga. 421 (Ga. 2014) (prejudice prong required in ineffective assistance claims)
- Martin v. Barrett, 279 Ga. 593 (Ga. 2005) (defendant bears burden to show trial strategy constitutes reasonable conduct)
- United States v. Hill, 643 F.3d 807 (11th Cir. 2011) (discrepancies in witness testimony not automatically fatal to convictions)
- Smith v. Groose, 205 F.3d 1045 (8th Cir. 2000) (State’s use of witness testimony across trials did not render convictions due process violations)