Ledford v. State, 289 Ga. 70

Ledford was convicted of Jennifer Ewing's murder and related offenses, and the jury recommended a death sentence for the murder.
The trial court imposed death for malice murder and consecutive prison terms for other offenses, including three aggravated batteries.
The death was caused by asphyxiation stemming from the attack, with three aggravated battery injuries occurring during the same incident.
The trial court admitted evidence of two similar transactions and various pretrial and trial conduct issues during guilt/innocence and sentencing phases.
The Georgia Supreme Court vacated Ledford's aggravated battery convictions but affirmed all other convictions and sentences, including the death sentence for murder.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether aggravated battery convictions must merge with each other.	Ledford argues merger applies to aggravated batteries.	State argues three batteries each involved different conduct; no merger.	Convictions on aggravated battery counts must be vacated.
Whether aggravated battery counts merge into the murder conviction.	Ledford contends same conduct should merge with malice murder.	State maintains separate elements allow non-merger; but statutory rules may require merger.	Merger not required under the
Whether pre-trial publicity and venue denial were improper.	Ledford contends venue should have been changed due to prejudicial publicity.	Court did not abuse discretion; voir dire and juror questioning mitigated prejudice.	No error in denying change of venue.
Whether Georgia's death penalty scheme and its application in this case were unconstitutional.	Ledford asserts discriminatory application and procedural flaws.	Court finds no constitutional violation; procedures and narrowing/statutory aggravators are valid.	No reversible error in death penalty scheme or its application.
Whether the method of lethal injection is unconstitutional.	Ledford argues lethal injection method is unconstitutional.	Court repeatedly rejects challenges to Georgia's method.	Method of execution upheld.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard for due process review)
Drinkard v. Walker, 281 Ga. 211 (Ga. 2006) (explains required-evidence and included-offense analysis; blocks improper multiple convictions)
Gissendaner v. State, 272 Ga. 704 (Ga. 2000) (voir dire and venue considerations; standard for juror qualification)
Waits v. State, 282 Ga. 1 (Ga. 2007) (same-conduct analysis for merger and inclusion rules)
Linson v. State, 287 Ga. 881 (Ga. 2010) (discussion of when similar-conduct evidence affects merger/eligibility)
Gregg v. Georgia, 428 U.S. 153 (U.S. 1976) (context for capital punishment and narrowing mechanisms)
Arrington v. State, 286 Ga. 335 (Ga. 2010) (proportionality review and death-penalty standards)