Poole v. State, 291 Ga. 848

Tammy Poole was convicted of malice murder and multiple related offenses after trial in 2008.
The State’s case included eyewitness/inmate testimony and forensic evidence linking a Remington 22 rifle to the fatal wound.
Poole initially claimed the victim shot himself, then various explanations involving the rifle and struggle, and suggested the victim’s suicide to others.
Evidence included testimony about a threatened divorce, alleged domestic violence, and Poole’s prior felonies.
The trial court admitted prior convictions for purposes related to the felon-in-possession charge and felony murder predicate.
Poole argued ineffective assistance of counsel, improper jury instructions, evidentiary rulings, and other trial errors on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Poole contends the evidence, especially the inmate testimony, is insufficient.	State argues circumstantial evidence excluding reasonable doubt supports guilt.	Evidence sufficient to support guilt beyond reasonable doubt.
Bifurcation of felon-in-possession	Trial court erred by not bifurcating the felon-in-possession count from felony murder.	Bifurcation unnecessary because felon-in-possession underpins felony murder.	No error; bifurcation denied.
Juror for-cause/disclosure and voir dire	Juror should have been excused for cause due to relationships and preconceived opinions.	Trial court acted within discretion; no fixed opinion shown.	No reversible error; court did not abuse discretion.
Ineffective assistance of trial counsel	Counsel failed to object to improper opening, evidence, and investigative decisions.	Counsel’s strategy and reasonable investigations supported by record; not deficient.	No ineffective assistance; claims rejected with deference to trial strategy.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review requires whether evidence proves guilt beyond reasonable doubt)
Brooks v. State, 281 Ga. 514 (Ga. 2007) (credibility of witness for jury; reasonableness standard for circumstantial evidence)
Kim v. Walls, 275 Ga. 177 (Ga. 2002) (trial court must conduct adequate voir dire; burden to show partiality rests with movant)
Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (reasonableness of investigation in ineffective-assistance claims; deference to counsel's strategic choices)
Perry v. State, 274 Ga. 236 (Ga. 2001) (prosecutor may illustrate evidence within the record during closing arguments)
Finley v. State, 286 Ga. 47 (Ga. 2009) (felony murder underlying felony relationships discussed)
Head v. State, 253 Ga. 429 (Ga. 1984) (underlying felony can serve as predicate in felony-murder charge)