Redding v. State
297 Ga. 845
| Ga. | 2015Background
- Redding was convicted in Georgia state court of murder and related offenses for killings in 2007; conviction affirmed on direct appeal.
- Evidence at trial included eyewitness accounts, video interviews, and ballistics tying to shootings in Atlanta.
- Jura Tye shooting (September 2007) was admitted as similar-transaction evidence to demonstrate modus operandi.
- Witness Collins testified and was impeached with a pretrial video in which he described Redding as gang-affiliated.
- Defense challenged the Tye evidence, Collins impeachment, and other trial rulings; the court reviewed under evidentiary and ineffective-assistance standards.
- Redding argues ineffective assistance of counsel based on specific decisions and strategy during trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Jura Tye evidence | Redding seeks exclusion of Tye evidence as insufficiently similar | State contends similarities show MO and course of conduct | Admissible for proper purpose; no abuse of discretion. |
| Impeachment by Collins gang reference video | Video admission unfairly impugns character | Statement relevant for impeachment; not improper character attack | Proper impeachment; admission upheld. |
| Admission of jailhouse assault evidence | Evidence improperly prejudicial; trial counsel ineffective for not objecting | Evidence supported by intimidation theory; not deficient performance | Evidence admissible; no deficient performance. |
| Trial counsel’s cross-examination strategy on Thornton | Counsel erred in eliciting gang-claim remarks | Strategy aimed to attack credibility without undue prejudice | Not deficient performance; strategy within broad discretion. |
| Overall ineffective-assistance standard application | Strickland prejudice established | No prejudice shown under Strickland | No reasonable probability of different result; claims fail. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard)
- Wilson v. State, 293 Ga. 508 ( Ga. 2013) (similar transaction admissibility focus on similarities)
- Johnson v. State, 289 Ga. 22 ( Ga. 2011) (similar transactions; focus on similarities)
- Abdullah v. State, 284 Ga. 399 ( Ga. 2008) (similar transactions; proximity and lack of provocation)
- Moore v. State, 288 Ga. 187 ( Ga. 2010) (prior shooting admissible under similar-transaction reasoning)
- Salahuddin v. State, 277 Ga. 561 ( Ga. 2004) (similar conduct and escalation in multiple shootings)
- Wolfe v. State, 273 Ga. 670 ( Ga. 2001) (gang affiliation admissible when relevant to issue in case)
- Mosely v. State, 269 Ga. 17 ( Ga. 1998) (defense cannot object to elicited testimony by strategy choice)
- Simmons v. State, 271 Ga. 563 ( Ga. 1999) (impeachment and credibility considerations)
- Arnold v. State, 292 Ga. 268 ( Ga. 2013) (presumption of reasonable performance in Strickland claims)
- Romer v. State, 293 Ga. 339 ( Ga. 2013) (standard for evaluating trial counsel performance)
- Strickland v. Washington, 466 U.S. 668 ( U.S. 1984) (deficient performance and prejudice prong for ineffective assistance)