Matthews v. State, 301 Ga. 286

On July 11, 2012, two-year-old Jadien Harvey died of blunt-force head trauma; four-year-old Ashton Capers sustained multiple injuries (perforated intestine, fractured tibia, spinal injury, genital injury) consistent with physical abuse.
The children lived with their mother Ashley Harvey and appellant Kemra Matthews, who cared for the children when Ashley worked; witnesses observed Ashton vomiting repeatedly earlier that day and Matthews threatening to "beat" him.
Ashton, while hospitalized and later at trial, told family members and trained interviewers without apparent coaching that Matthews hit him (stomach, bottom, back, genitalia) and hit Jadien; the forensic interviewer testified Ashton was not coached and demonstrated assaults with gestures.
Medical examiner testified Jadien’s acute head injuries (including a skull fracture and optic nerve bleeding) were from blunt force and would have rendered him immediately unconscious.
A Clayton County jury convicted Matthews of felony murder and multiple related counts; he was sentenced to life without parole plus concurrent terms. Matthews appealed, challenging sufficiency of the evidence and counsel’s failure to present a defense expert on forensic interviewing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to convict of felony murder and related counts	State: physical injuries, medical examiner’s cause of death, child’s out-of-court statements, and other physical evidence support convictions	Matthews: (argued on appeal) evidence insufficient to support convictions	Affirmed: viewing evidence in light most favorable to verdict, evidence was sufficient under Jackson v. Virginia
Ineffective assistance for not presenting defense expert witness on child forensic interviewing	Matthews: trial counsel was deficient for not calling an expert to rebut State experts and to show Ashton was coached	State: decision not to call an expert was reasonable trial strategy; counsel cross-examined and argued alternative theories	Affirmed: counsel’s choice was within reasonable professional judgment; appellant did not show deficient performance or prejudice

Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence)
Stewart v. State, 296 Ga. 448 (2015) (Georgia sufficiency review cited)
Pruitt v. State, 282 Ga. 30 (ineffective assistance standard articulated)
Wright v. State, 291 Ga. 869 (if one prong of Strickland test fails, court need not address the other)
Eason v. State, 283 Ga. 116 (decision to present expert is typically trial strategy)
Jones v. State, 296 Ga. 561 (burden on defendant to show counsel deficient)