Rafi v. State, 289 Ga. 716

Bryan Evans was killed during an attempted drug purchase using a counterfeit $100 bill at Rafi's house.
Eyewitness testified Rafi drove up, argued about the counterfeit money, pistol-whipped Evans, then shot him as he lay on the ground.
Evans died from a gunshot wound to the neck causing airway collapse.
Rafi was arrested in 1998; indictment followed in 2001 for malice murder, felony murder, aggravated assault, and firearm possession.
Trial occurred in 2007 after a prolonged pretrial period and multiple public defenders; conviction on all charges; sentence imposed.
Defendant argued speedy-trial, ineffective assistance, evidentiary/mistrial issues, and due-process concerns about a proposed order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Speedy trial violation was improper	Rafi asserts a Barker-Doggett based delay prejudiced him.	State contends delay not presumptively prejudicial or properly weighed.	Delay presumptively prejudicial; court affirmed denial of speedy-trial claim after balancing factors.
Ineffective assistance of counsel	Counsel failed to interview witnesses, present Chandler evidence, and obtain more time.	Counsel's conduct fell within professional norm; no deficient performance proven.	Trial court did not err; claims rejected.
Curative instruction versus mistrial for witness testimony	Testimony violated trial court instruction and warranted mistrial.	No intentional elicitation; curative instruction sufficed.	No mistrial; curative instruction adequate and countered potential harm.
Due process reformulation of motion-for-new-trial order	Ex parte verbatim adoption of State's proposed order violated due process.	Findings were not clearly erroneous; process not fundamentally unfair.	No due-process violation; order affirmed.

Barker v. Wingo, 407 U.S. 514 (1972) (two-tier speedy-trial analysis with Barker factors)
Doggett v. United States, 505 U.S. 647 (1992) (presumptive prejudice triggers balancing test)
Brewington v. State, 288 Ga. 520 (2011) (presumptive prejudice due to lengthy delay; Barker-Doggett applied)
Johnson v. State, 268 Ga. 416 (1997) (demonstrated speedy-trial demand timing weighs against defendant)
Brannen v. State, 274 Ga. 454 (2001) (failure to demand trial weighed against defendant)
Brinson v. State, 289 Ga. 551 (2011) (mistrial standards and fair-trial considerations in Georgia)
Chandler v. State, 261 Ga. 402 (1991) (admissibility of certain violent-act evidence in justification cases)
Anderson v. City of Bessemer City, 470 U.S. 564 (1985) (ex parte findings and due process considerations)