Naples v. State, 308 Ga. 43

17-month-old Kaylee Johnson was found unresponsive at the bottom of Naples’s basement stairs on Oct. 14, 2012, and later died of a skull fracture and brain swelling; medical testimony concluded injuries were inconsistent with an accidental fall.
Naples was indicted on murder (felony murder predicated on first-degree cruelty to children) and related charges; a Cherokee County jury convicted him of felony murder, cruelty to children, aggravated assault, and aggravated battery; he received life without parole plus consecutive terms.
The State introduced jailhouse informant testimony recounting Naples’s admissions that he became aggravated, covered Kaylee’s mouth, lost his temper, and threw her down the stairs (and discussed efforts to conceal or blame others).
The State also introduced Rule 404(b) "other acts" evidence showing Naples’s history of violent conduct toward others (his two children and several adult family members) to prove intent and absence of accident.
Naples appealed, arguing (1) erroneous admission of 404(b) evidence and (2) ineffective assistance of trial counsel; the Georgia Supreme Court reviewed admissibility, harmlessness, and Strickland claims and affirmed the convictions.

Issue	State's Argument	Naples's Argument	Held
Admissibility of Rule 404(b) evidence to prove intent/lack of accident	Other-acts (abuse of G.N. and A.T. and others) show same state of mind and negate accident	The prior acts are dissimilar or simply character evidence and unfairly prejudicial	Admission as to the two children was relevant to intent and allowed; evidence as to some adults, if erroneous, was harmless error
Use of other-acts to prove identity vs intent	Offered to prove intent/absence of mistake, not identity	Lack of physical similarity defeats admissibility	When offered for intent, only similarity of state of mind is required; thus admissible for that purpose
Rule 403 balancing (prejudicial vs probative; cumulative)	Evidence highly probative: shows supervisory control, comparable circumstances, and rebuts accident inference	Testimony was cumulative and unduly prejudicial	Trial court did not abuse discretion under Rule 403; probative value was not substantially outweighed by prejudice
Ineffective-assistance claims (failure to object, eliciting testimony, impeachment, limiting instruction)	Trial strategy justified choices; objections or different tactics would not likely change outcome	Counsel’s omissions and elicited testimony were deficient and prejudicial	Strickland not satisfied: counsel’s decisions were reasonable strategy or non-deficient, and Naples failed to show prejudice; convictions affirmed

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency of the evidence)
Bradshaw v. State, 296 Ga. 650 (Rule 404(b) three-part admissibility test)
State v. Jones, 297 Ga. 156 (deference to trial court on 404(b) rulings)
Brooks v. State, 298 Ga. 722 (similarity requirement when extrinsic evidence offered for identity)
Kirby v. State, 304 Ga. 472 (lesser similarity required when extrinsic acts prove intent)
Banta v. State, 282 Ga. 392 (mental state for cruelty to children defined)
Rivera v. State, 295 Ga. 380 (harmless error standard for nonconstitutional error)
Harris v. State, 304 Ga. 276 (other-acts admissibility and harmlessness)
Hood v. State, 299 Ga. 95 (admissibility/harm analysis for other-acts)
Olds v. State, 299 Ga. 65 (Rule 403 exclusion is extraordinary remedy)
McNair v. State, 296 Ga. 181 (strategic trial decisions rarely prove ineffective assistance)
Strickland v. Washington, 466 U.S. 668 (establishes ineffective-assistance standard)