Lockhart v. State, 298 Ga. 384

Joe Lockhart was tried and convicted of malice murder and possession of a firearm during the commission of a felony for the shooting death of Bernard Campbell; sentence: life plus 5 years.
Facts supporting convictions: Lockhart, seeking money from a sale of rims, located Campbell at a park, entered a third party’s vehicle, pointed a revolver, directed that vehicle to follow Campbell, exited, shot Campbell multiple times, then returned to the vehicle; Campbell died seven weeks later.
At voir dire a prospective juror (Juror 18) stated before the whole panel that he knew Lockhart from working 14 years at the Fulton County Sheriff’s Department, working on maximum security dealing with violent criminals; that juror was later excused for cause outside the panel.
Defense counsel considered asking the court to instruct the panel about Juror 18’s contact with Lockhart or to seek a replacement panel, but opted not to request a new panel and declined the instruction as trial strategy.
Lockhart argued on appeal that counsel was constitutionally ineffective for failing to seek dismissal of the entire panel based on Juror 18’s remark; he also challenged sufficiency of the evidence.
The Supreme Court of Georgia affirmed, holding the evidence sufficient and finding no ineffective assistance because counsel’s choices were reasonable strategy and Lockhart could not show prejudice from not obtaining a new panel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support murder and firearm convictions	Evidence did not establish guilt beyond a reasonable doubt	State: eyewitness and forensic evidence supported convictions	Affirmed — evidence authorized the convictions under Jackson v. Virginia
Ineffective assistance for not seeking dismissal of entire jury panel after Juror 18's remark	Lockhart: counsel should have sought a new panel because Juror 18’s statement that he knew Lockhart from detention prejudiced the panel	State: counsel reasonably pursued strategy to keep the remaining panel; Juror 18’s comment did not link Lockhart to other criminality and produced no prejudice	Affirmed — counsel’s decision was within reasonable professional judgment and Lockhart failed to show a reasonable probability of a different outcome

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
Smith v. Francis, 253 Ga. 782 (ineffective-assistance Strickland framework applied in Georgia)
Strickland v. Washington, 466 U.S. 668 (two-prong test for ineffective assistance)
Redding v. State, 297 Ga. 845 (deference to tactical decisions; patently unreasonable standard)
Robinson v. State, 277 Ga. 75 (appellate review accepts trial court’s factual findings)
Kinder v. State, 284 Ga. 148 (jury panel dismissal precedent cited)
Sharpe v. State, 272 Ga. 684 (jury panel dismissal precedent cited)
Mohamud v. State, 297 Ga. 532 (hindsight cannot be used to condemn counsel strategy)
Upton v. Parks, 284 Ga. 254 (juror strike and acceptance are strategic decisions)
Baker v. State, 295 Ga. App. 162 (trial-strategy deference on juror choices)
Prince v. State, 277 Ga. 230 (keeping a juror on panel can be reasonable strategy)
Williams v. State, 292 Ga. 844 (prejudice requirement for jury contamination claims)
Edwards v. State, 282 Ga. 259 (no requirement to excuse entire panel when comments don't characterize defendant as criminal)
Bright v. State, 292 Ga. 273 (being jailed in relation to the case does not place defendant’s character in evidence)
Bennett v. State, 266 Ga. App. 502 (no inherent prejudice from juror comment that defendant was in jail awaiting trial)
Malcolm v. State, 263 Ga. 369 (merger and sentencing principles referenced)