Mangrum v. State
291 Ga. 529
| Ga. | 2012Background
- Mangrum was convicted in 2002 of multiple crimes related to Katie Hamlin's death, including three counts of felony murder and other offenses.
- On appeal this Court previously rejected most arguments but remanded the ineffective assistance claim for a hearing.
- A 2011 hearing on the ineffective assistance claim featured only trial counsel Jimmy Berry as a witness.
- Berry had suggested the victim’s death could be a seizure caused by medications, notably Risperdal, though no medical records or experts were presented at the hearing.
- The trial court denied the claim in 2011, and Mangrum appealed the ruling.
- The court held that, under Strickland, appellant must show deficient performance and prejudice; lack of medical records/experts meant no proven prejudice, so relief was denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel's failure to procure medical evidence was deficient performance. | Mangrum | Mangrum | Denied; no deficient performance shown |
| Whether there was prejudice to the outcome from the absence of medical evidence. | Mangrum | Mangrum | Denied; mere speculation insufficient to show prejudice |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (standard for ineffective assistance of counsel)
- Watkins v. State, 289 Ga. 359 (Ga. 2011) (discussion of ineffectiveness standards)
- Dickens v. State, 280 Ga. 320 (Ga. 2006) (speculation insufficient to establish prejudice)
- Hambrick v. Brannen, 289 Ga. 682 (Ga. 2011) (rejection of ineffective assistance where nothing substantial offered)
- Mangrum v. State, 285 Ga. 676 (Ga. 2009) (remand for ineffective assistance claim; appellate posture)