Lord v. State
304 Ga. 532
Ga.2018Background:
- Defendant Manuel G. Lord and four accomplices conspired to rob Chauncey Fleming on Feb. 5, 1996; three people (Fleming, McMillian, Turner) were subsequently shot and killed, each shot by a different accomplice.
- The case went cold until Nov. 24, 1997, when co-defendant Braithwaite’s wife (Miller) reported nonpublic crime-scene details and implicated the group; ballistics later tied a gun recovered after Lord and Ward’s Feb. 16, 1996 arrest to the murders.
- Ward and Davis (accomplices) testified at trial corroborating the plan, killings, and chain of possession of the murder weapon; Miller also testified about Braithwaite’s out-of-court statements.
- Lord was convicted after a jury trial of multiple counts (malice murder, felony murder, aggravated assault, firearm possession) and sentenced to consecutive life and term sentences; he appealed pro se from denial of his motion for new trial.
- The Supreme Court of Georgia affirmed, rejecting challenges including sufficiency of the evidence, alleged jury-selection prejudice after a co-defendant’s plea, Batson challenge, Bruton/confrontation/co‑conspirator hearsay claims, ineffective-assistance claims, and a speedy-appeal claim.
Issues:
| Issue | Plaintiff's Argument (Lord) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Sufficiency of evidence | Verdict against weight; accomplice testimony unreliable | Accomplice testimony, Miller’s tips, and ballistics made ample proof beyond a reasonable doubt | Affirmed; evidence sufficient (Jackson standard) |
| Jury selection after co-defendant pleaded guilty | Allowing Davis and his counsel to appear to continue voir dire prejudiced Lord and warranted mistrial/new panel | Parties agreed to conceal plea; curative measures prevented prejudice; no inherent prejudice | Affirmed; trial court did not abuse discretion; procedure was nonprejudicial |
| Batson challenge to peremptory strikes | Prosecutor struck two African‑American jurors; argued discrimination | Prosecutor gave race‑neutral reasons (prior relationship and expressed views) | Affirmed; court credited State’s race‑neutral explanations and found no discriminatory intent |
| Admission of Braithwaite’s statements (Bruton / co‑conspirator hearsay / Confrontation Clause) | Statements through Miller violated Bruton and confrontation; State failed to establish conspiracy prima facie | Statements were non‑testimonial, admissible under co‑conspirator exception (conspiracy shown by accomplice testimony), and not barred by Confrontation Clause | Affirmed; no Bruton or Confrontation error and co‑conspirator exception applied |
| Ineffective assistance of counsel (multiple alleged failures) | Counsel failed to object to various comments, golden‑rule argument, improper testimony, and delayed impeachment of Miller | Alleged failures were either factually inaccurate, would have been meritless objections, or were reasonable tactical choices; impeachment evidence was ultimately presented | Affirmed; Strickland not satisfied — no deficient performance or prejudice |
| Speedy appeal claim | Appellate delay harmed Lord’s ability to litigate (lost witnesses, evidence, memory) | Delay acknowledged but no specific prejudice shown to appellate arguments or retrial rights | Affirmed; modified Barker factors applied and Lord failed to show required prejudice |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence review)
- Batson v. Kentucky, 476 U.S. 79 (three‑step test for race‑based peremptory challenges)
- Bruton v. United States, 391 U.S. 123 (limitations on admitting non‑testifying co‑defendant statements)
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance two‑prong test)
- Barker v. Wingo, 407 U.S. 514 (speedy trial framework applied to delay claims)
- Chatman v. Mancill, 280 Ga. 253 (modified Barker factors for appellate delay in nondeath cases)
- Coleman v. State, 301 Ga. 720 (Batson framework and deferential review of trial court credibility findings)