Pepe-Frazier v. State, 331 Ga. App. 263

Pepe-Frazier was convicted by jury of trafficking for sexual servitude, pimping, aggravated child molestation, enticing a child for indecent purposes, and contributing to the delinquency of a minor.
The offenses involved a 14-year-old victim who was coerced into prostitution over several weeks beginning in April 2009.
The State presented testimony from the victim, another former prostitute, and Harvey White, corroborating a pattern of recruitment, coercion, and violence by Pepe-Frazier.
During the investigation and trial, the defense challenged evidentiary rulings and asserted ineffective assistance of counsel on multiple grounds.
The trial court admitted a prior consistent statement by the victim, which the court later held was erroneous but harmless.
The trial court qualified two experts on commercial sexual exploitation of children and pimping culture, which Pepe-Frazier challenged as error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of prior consistent statement	Pepe-Frazier argues the statement was hearsay and improperly bolstered credibility.	Pepe-Frazier contends the trial court erred in admitting the statement.	Harmless error; did not contribute to the verdict.
Qualification of expert witnesses	State properly qualified experts on commercial sexual exploitation and pimping culture.	Trial court erred in qualifying the experts.	Court did not abuse discretion; even if error, not likely to affect the outcome.
Ineffective assistance—failure to object to hearsay/prior statements	Counsel was ineffective for not objecting to inadmissible hearsay and prior statements.	Counsel's performance was deficient and prejudicial.	Not proven; objections would have been meritless or non-prejudicial.
Ineffective assistance—failure to request lesser-included instruction	Counsel should have requested a lesser-included offense instruction (child molestation).	Failure to request was ineffective assistance.	No ineffective assistance; evidence did not raise the lesser offense as a real issue.
Constitutional challenge to sentence and allocution	Life sentence for aggravated child molestation and denial of allocution were unconstitutional or ineffective assistance.	Sentence and allocution handling were proper; no cruel-and-unusual issue.	Sentence not grossly disproportionate; allocution claim unfounded; no merit to ineffective-assistance challenge.

Muse v. State, 323 Ga. App. 779 (Ga. App. 2013) (evidence sufficiency and corroboration considerations)
Johnson v. State, 328 Ga. App. 702 (Ga. App. 2014) (admission of prior consistent statement when no fabrication charge)
Adams v. State, 288 Ga. 695 (Ga. 2011) (proportionality of sentences; rarity of successful challenges)
Gordon v. State, 327 Ga. App. 774 (Ga. App. 2014) (defense strategy and lesser-included offenses)
Porras v. State, 295 Ga. 412 (Ga. 2014) (failure to object to meritless issue cannot amount to ineffective assistance)