Scandrett v. State, 293 Ga. 602

On December 16, 1997, Tyrone Chambers was shot and killed at Thomasville Heights Apartments; Deavis Reese saw the shooter and later identified Scandrett at trial.
Scandrett approached Chambers and Reese, displayed a Glock 9mm, and fired; Chambers died from multiple gunshot wounds.
About a year later, Officer Eric Minter stopped Scandrett after an abrupt turn at a roadblock and found a loaded Glock 9mm in the car; ballistics matched shell casings from the murder scene to that Glock.
Witnesses and a friend (Mekael Daniels) testified that Scandrett admitted shooting Chambers and identified the gun; another witness described a shooter of medium build using a Glock.
Procedurally: indicted in 2003; first trial (Apr 2006) mistrial; retrial (May 23, 2006) resulted in convictions for malice murder and firearms offenses; felony murder convictions vacated by operation of law; motion for new trial denied and appeal to the Georgia Supreme Court followed.

Issue	Scandrett's Argument	State's Argument	Held
Sufficiency of evidence	Conviction not supported	Evidence (identifications, admissions, ballistics) sufficient	Affirmed — evidence sufficient under Jackson v. Virginia
In-court ID after suppressed out-of-court ID	In-court ID tainted by prior suggestive show-up	In-court ID had independent origin; witness saw shooter closely	Affirmed — trial court reasonably found independent origin; in-court ID admissible
Suppression of gun seized after traffic stop	Stop illegal (no lawful basis for stopping turn) so seizure inadmissible	Officer credible that other cars were behind, lawful stop for improper turn	Affirmed — credibility finding for officer was not clearly erroneous; motion to suppress denied
Ineffective assistance — failure to introduce driver's license photo	Counsel deficient for not using photo showing short hair to rebut braid testimony; prejudiced outcome	No evidence counsel knew of photo; jury already heard testimony of short hair; no reasonable probability of different outcome	Affirmed — Strickland standards not met; no reversible ineffective assistance

Jackson v. Virginia, 443 U.S. 307 (establishes standard for reviewing sufficiency of evidence)
Stringer v. State, 285 Ga. 842 (2009) (trial-court suppression findings construed favorably and credibility findings upheld unless clearly erroneous)
Wilson v. State, 275 Ga. 53 (2002) (in-court identification admissible if it has independent origin despite tainted pretrial ID)
Strickland v. Washington, 466 U.S. 668 (establishes two-prong ineffective assistance test: deficient performance and prejudice)
Fuller v. State, 277 Ga. 505 (addresses application of Strickland in Georgia)
Robinson v. State, 277 Ga. 75 (court accepts trial-court factual findings and independently applies legal principles)
Wright v. State, 291 Ga. 869 (addresses relevance of documentary evidence and reasonable probability standard in ineffective-assistance claims)
Malcolm v. State, 263 Ga. 369 (1993) (vacating felony murder convictions by operation of law)