Richards v. State, 306 Ga. 779

In May 2015 Abijah Richards and two co-indictees encountered the victim; Richards, armed with a 9mm Glock, instigated a robbery and shot the victim, who died from a gunshot wound.
Richards, Kamara, and Walker were indicted for malice murder, felony murder (aggravated assault), aggravated assault, armed robbery, and possession of a firearm during a felony; Kamara and Walker later pled guilty to voluntary manslaughter.
Richards was tried alone (Oct. 30–Nov. 3, 2017); the jury convicted on all counts and sentenced Richards to life plus consecutive terms for armed robbery and firearm possession.
On appeal Richards raised only ineffective-assistance-of-counsel claims: (1) failure to object to hearsay testimony from an investigating sergeant and eliciting additional hearsay on cross; and (2) failure to object to emotional/character testimony about the victim.
The trial court credited defense counsel’s testimony that these were strategic choices and concluded any deficiency was not prejudicial; the Georgia Supreme Court affirmed the denial of the motion for new trial.

Issue	Plaintiff's Argument (Richards)	Defendant's Argument (State)	Held
Failure to object to hearsay testimony from investigating sergeant (and eliciting more hearsay on cross)	Counsel was ineffective for permitting and eliciting hearsay that bolstered prosecution witnesses	Counsel made a reasonable strategy to use sergeant’s statements to expose inconsistencies and highlight doubt; trial court credited this	Trial counsel’s choice was a reasonable strategic decision; no deficient performance or prejudice shown; claim rejected
Failure to object to emotional/character testimony about the victim	Counsel was ineffective for not objecting to testimony that portrayed the victim as virtuous and emotionally influenced the jury	Counsel reasonably omitted objections to avoid appearing insensitive and to avoid drawing juror attention to non-crucial testimony	Trial court reasonably found tactic non-deficient; omission was a reasonable tactic and not prejudicial; claim rejected

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence review)
Strickland v. Washington, 466 U.S. 668 (two-prong ineffective-assistance standard)
Slaton v. State, 303 Ga. 651 (Georgia application of Strickland)
Davis v. State, 306 Ga. 140 (evaluating counsel reasonableness without hindsight)
Wright v. State, 291 Ga. 869 (appellate review: accept trial court factual findings; review legal application independently)
Marshall v. State, 299 Ga. 825 (non-objection to hearsay can be reasonable strategy)
Green v. State, 291 Ga. 579 (strategy to withhold objection to exploit inconsistencies)
Kilpatrick v. State, 276 Ga. 151 (reasonable tactic to avoid objections that might appear insensitive and are not crucial)