Ruffin v. State, 296 Ga. 262

Ruffin, an inmate, was convicted of malice murder for stabbing fellow inmate Darrell Blackwelder during a prison-yard altercation and sentenced to life without parole.
Evidence: witnesses saw Ruffin chase and strike the victim, witnesses observed a knife-like object and Ruffin wearing gloves; bloody glove, blood-stained shoes/slacks, and a ripped name tag linked to Ruffin were recovered; victim died from a stab wound to the abdomen.
Ruffin claimed self-defense, saying the victim charged him with a shank and Ruffin accidentally stabbed the victim after wrestling for the weapon.
Trial court convicted on malice and felony murder (felony murder later vacated as a matter of law); Ruffin appealed challenging jury instructions, polling, and counsel effectiveness.
The trial court recharged the jury on malice, felony murder, and self-defense after a jury question; later gave an Allen charge; jury returned a unanimous verdict without Ruffin requesting a poll.

Issue	Ruffin's Argument	State's Argument	Held
Whether the trial court erred by not instructing on voluntary manslaughter/mutual combat	Trial court should have charged voluntary manslaughter/mutual combat (Drake) despite no request	Evidence did not support mutual combat; Ruffin testified self-defense and denied intent to kill	No error; instruction not warranted because evidence did not support mutual combat or voluntary manslaughter
Whether failure to poll the jury required reversal	Jury confusion and delay warranted polling to verify unanimity despite no request	Polling not required absent timely request; court twice instructed unanimity and verdict not suspect	No error; no timely request and no evidence verdict was non-unanimous
Whether counsel was ineffective for not requesting manslaughter/mutual combat charge	Counsel’s omission prejudiced Ruffin	No prejudice because those charges were not supported by the evidence	No ineffective assistance; no prejudice under Strickland
Whether counsel was ineffective for not requesting jury poll	Counsel should have requested poll after jury question and delay	No prejudice shown; courts routinely reject ineffective assistance claims for failure to poll	No ineffective assistance; no prejudice established

Jackson v. Virginia, 443 U.S. 307 (constitutional sufficiency review standard)
Drake v. State, 221 Ga. 347 (1965) (mutual combat/voluntary manslaughter principles)
Mathis v. State, 196 Ga. 288 (mutual combat requires mutual willingness to fight)
Pulley v. State, 291 Ga. 330 (defendant’s self-defense testimony can preclude manslaughter instruction)
Coleman v. State, 256 Ga. 306 (jury poll not mandated unless requested)
Strickland v. Washington, 466 U.S. 668 (ineffective assistance two-prong test)
Lupoe v. State, 284 Ga. 576 (no ineffective assistance for failing to request unwarranted charge)
Marshall v. State, 285 Ga. 351 (Georgia courts reject ineffective-assistance claims based on failure to poll)