Leonard v. State, 292 Ga. 214

Leonard was convicted of malice murder and a firearm-charge arising from the August 23, 2006 shooting deaths of Darr and Cates.
Darr drove and Cates sat in the front seat when Leonard shot at them during a dispute over drugs Leonard was selling.
The vehicle fled, crashed, and Darr died from a chest wound; Cates died from wounds to the back.
Leonard later stated the men’ s drugs had fallen inside the vehicle and claimed they had to be stopped from “pull[ing] off” on him.
A .25 caliber pistol used in the shootings was recovered from Leonard’s apartment window area after police arrested him.
Leonard challenged the admission of statements, jury questions, and claims of ineffective assistance of counsel; the trial court denied relief and the convictions were affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support malice and felony murder	Leonard argues the evidence did not prove malice murder or related felonies beyond reasonable doubt	State contends the record supports a reasonable jury verdict	Evidence sufficient to sustain convictions beyond reasonable doubt
Voluntariness of Leonard’s recorded statement	Leonard claims the statement was coerced by drug use and a promised light sentence	State asserts the confession was voluntary, corroborated by the recording and trial court’s findings	Statement admitted; no clear error in voluntariness determination
Voir dire limitations and juror-for-cause challenges	Leonard contends the court erred in denying his challenges to jurors for cause	Court properly exercised discretion; responses did not demonstrate inability to be impartial	No abuse of discretion in denying challenges; jurors remained qualified
Ineffective assistance of counsel	Counsel failed to seek bifurcation and to secure transcripts/experts affecting outcomes	Counsel’s decisions were reasonable; failures lacked prejudice	No reversible error; claims insufficient to establish Strickland prejudice

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review requires evidence viewed in light most favorable to the verdict)
Pickren v. State, 272 Ga. 421 (Ga. 2000) (credibility determinations for confessions reviewed for clear error)
Farris v. State, 290 Ga. 323 (Ga. 2012) (voluntariness of confessions based on demeanor and circumstances)
State v. Folsom, 286 Ga. 105 (Ga. 2009) (voluntariness of statements; use of video and transcripts in analysis)
Corza v. State, 273 Ga. 164 (Ga. 2000) (voir dire discretion; not every equivocal answer requires strike for cause)
Shiver v. State, 276 Ga. 624 (Ga. 2003) (deference to trial court’s voir dire rulings)
Nance v. State, 280 Ga. 125 (Ga. 2005) (appellate deference to trial court findings on voir dire)