Norton v. State, 320 Ga. App. 327

Norton was convicted in Cherokee County of trafficking in methamphetamine, possession of methamphetamine on his person and in his urine, and possession of a drug related object.
Appellant argues for a new trial based on (1) admission of similar transaction evidence from an illegal search and (2) a Miranda-violation during a police interview; he also asserts ineffective assistance of trial counsel.
Emergency-room search of Norton followed hospital protocol, uncovering a meth pipe, 1.03 grams of meth, and 47.6 grams of meth; a urine test later tested positive for methamphetamine.
Police later executed a warrant at Norton’s girlfriend’s home related to meth, during which Norton was frisked, a meth pipe was found, and he gave a urine sample after an on-scene interview.
During trial, the State admitted similar transaction evidence from the April 2009 warrant execution at Norton’s girlfriend’s home; the warrant wording discrepancy (methamphetamine vs marijuana) was deemed non-material by the trial court.
Norton signed a Miranda waiver after an officer explained rights; he did not clearly invoke the right to remain silent, and the court found the waiver voluntary; a later ineffective-assistance claim was deemed procedurally barred or unpersuasive as to strategy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of similar transaction evidence	Norton	State	Denied; evidence admitted.
Miranda waiver and custodial statement	Norton	State	Waiver valid; statements admitted.
Ineffective assistance of counsel	Norton	State	No deficient performance; strategy reasonable.

Martinez v. State, 306 Ga. App. 512 (Ga. App. 2010) (standard for reviewing guilty verdicts on appeal)
Carlton v. State, 251 Ga. App. 339 (Ga. App. 2001) (credibility determinations reviewed on appeal)
Perez v. State, 283 Ga. 196 (Ga. 2008) (requires clear, unequivocal invocation to stop questioning)