Miller v. State
293 Ga. 638
Ga.2013Background
- Miller was convicted of malice murder, possession of a firearm during a felony, and possession of a firearm by a convicted felon after the July 26, 2008 shooting of Coverson.
- Miller testified he acted in self-defense during a confrontation in the basement; Coverson allegedly pulled a gun and a struggle ensued.
- The State's theory supported by ballistics and scene evidence indicated Miller shot Coverson after restraining him and demanding money.
- Miller challenged trial counsel for failing to investigate self-defense, to test firearms, and to inspect the interior of the home; counsel had limited access to interior due to a boarded-up, abandoned structure.
- The trial court and appellate review found counsel’s performance non-deficient given the evidence of self-defense, related investigations, and available resources.
- Miller was sentenced to life in prison for malice murder, plus consecutive terms for the firearm offenses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance standard | Miller claims counsel was deficient for not testing firearms or inspecting interior | Counsel acted within reasonable professional judgment and pursued viable defense options | No deficient performance; no reasonable probability of different outcome |
| Prejudice from counsel’s alleged omissions | Hindsight shows omitted actions could have aided defense | Record shows substantial defense efforts; omissions did not prejudice | No prejudice; Strickland standard not met |
| Sufficiency of the evidence | Evidence supports self-defense and shooting under the alleged circumstances | Evidence supports conviction beyond a reasonable doubt | Sufficient evidence supported verdicts |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective assistance standard)
- Johnson v. State, 290 Ga. 382 (Ga. 2012) (highly deferential standard for trial counsel effectiveness)
- State v. Worsley, 293 Ga. 315 (Ga. 2013) (trial counsel performance evaluated from counsel’s perspective)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard)