Richardson-Bethea v. State, 301 Ga. 859

Walter, an intellectually disabled adult, lived with Appellant under Lutheran Services of Georgia oversight.
Walter had a history of a unsteady gait, falls, and bruising inconsistent with a simple ground‑level fall.
March 2, 2013: Walter was found dead with extensive injuries; Appellant claimed seizures and falls as causes.
At trial, the State’s medical examiner Sperry testified to fatal brain swelling and abdominal injuries from multiple blows.
Appellant’s defense relied on character testimony and relationships; no defense expert was called at trial.
Post‑trial, Burton (forensic pathologist) offered mixed testimony; trial court denied new trial; Georgia Court affirmed substantial evidence and lack of prejudice from not calling Burton harmonized with Strickland.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel’s failure to retain an expert was ineffective	Richardson‑Bethea argues trial counsel’s failure prejudiced the defense	State contends Burton’s equivocal testimony could not have changed outcome	No reasonable probability of different verdict; no prejudice shown

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes performance and prejudice standards for ineffective assistance)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence review for reasonable doubt)
Robinson v. State, 277 Ga. 75 (Ga. 2003) (prejudice showing required; appellate independence in evaluating trial claims)
Davis v. State, 290 Ga. 584 (Ga. 2012) (prejudice from failure to call expert reviewed with analogous precedent)
Goodwin v. Cruz-Padillo, 265 Ga. 614 (Ga. 1994) (aforementioned prejudice standard for ineffective assistance)
Woods v. State, 275 Ga. 844 (Ga. 2002) (prejudice analysis in ineffective assistance context)
Showers v. Beard, 635 F.3d 625 (3d Cir. 2011) (post‑conviction expert testimony impact on prosecution theory)
Richey v. Bradshaw, 498 F.3d 344 (6th Cir. 2007) (post‑conviction expert testimony could undermine theory)
Hummel v. Rosemeyer, 564 F.3d 290 (3d Cir. 2009) (competency/credibility issues in post‑conviction context)