Seabolt v. Hall, 292 Ga. 311

Hall was convicted of murder and aggravated assault; conviction affirmed on direct appeal.
In habeas corpus, Hall challenged trial counsel’s handling of Alyssa Davis’s closed-circuit testimony and failure to raise the issue on appeal.
Habeas court applied a presumption of prejudice, treating the claim as a direct-appeal issue and granting relief on that basis.
Trial counsel did not object to Alyssa’s testimony procedure, nor was the issue raised on appeal; the record showed no objection at trial.
Court held the claims were procedurally defaulted and evaluated the ineffective-assistance claim under Strickland, requiring actual prejudice.
Court reversed the habeas judgment, concluding Hall failed to show actual prejudice and that the presumption of prejudice did not apply.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Presumption of prejudice in ineffective-assistance review	Hall argues presumption should apply on direct-appearance issues on appeal.	State contends no presumptive prejudice when reviewing appellate counsel’s decisions in this context.	Presumption of prejudice does not apply; must show actual prejudice.
Procedural default and overcoming it	Hall argues her ineffective-assistance claim should avoid default and be considered on the merits.	State asserts procedural default remains; Hall failed to show cause and prejudice.	Claims are procedurally defaulted; no cause shown to overcome default.
Actual prejudice showing	Hall could have assisted counsel during Alyssa’s questioning, potentially changing trial results.	Counsel already knew the relevant issues (Alyssa’s letter, fear, coaching) and had this information; lack of prejudice.	Hall failed to demonstrate a reasonable probability of a different outcome; no actual prejudice.

Griffin v. Terry, 291 Ga. 326 (2012) (procedural default and prejudice considerations in habeas context)
Ward v. State, 288 Ga. 641 (2011) (presumption of prejudice on direct-appeal in certain ineffective-assistance contexts)
Sammons v. State, 279 Ga. 386 (2005) (presumed prejudice framework for direct-appeal ineffective assistance)
Upton v. Jones, 280 Ga. 895 (2006) (declining to presume prejudice where appellate ineffectiveness is raised)
Bridges v. State, 286 Ga. 535 (2010) (rejection of ineffectiveness-based prejudice without showing actual prejudice)
Peterson v. State, 284 Ga. 275 (2008) (same standard for prejudice in appellate context)
Greer v. Thompson, 281 Ga. 419 (2006) (actual prejudice standard for ineffective-assistance claims)
Walker v. Hagins, 290 Ga. 512 (2012) (Strickland performance and prejudice framework in Georgia)
Chatman v. Mancill, 280 Ga. 253 (2006) (reasonable-decision standard for appellate counsel’s strategy)
Turpin v. Todd, 268 Ga. 820 (1997) (causation-based consideration in procedural default contexts)