Seabrooks v. State, 306 Ga. 670

In Sept. 2016 a DeKalb County grand jury indicted DeAndre Seabrooks for malice murder, two theories of felony murder, aggravated assault, possession of a firearm by a convicted felon, and possession of a firearm during a felony; a jury convicted him and he received life without parole plus consecutive weapon sentences.
Evidence at trial: witnesses (Brawner and Malcolm) saw Seabrooks fire a long/military-style rifle toward an apartment entrance where the victim stood; one witness saw Seabrooks mouth, “They gone quit f*g with me.”
Ballistics tied the homicide to an AK-47 or SKS-style rifle; matching ammunition was found in locations connected to Seabrooks.
Jailhouse phone recordings showed Seabrooks arranging payment to a witness to change her story; Seabrooks also led police on a high-speed chase when officers attempted arrest.
On appeal Seabrooks raised only ineffective-assistance-of-counsel claims (many in a one-page list without analysis); the Court found most such claims abandoned or without merit and affirmed conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for failing to object to "gang activity" references	Seabrooks: counsel should have objected to testimony referencing gang activity	State/Trial ct: testimony was non-responsive, nonspecific to Seabrooks; counsel reasonably declined to object to avoid emphasizing it	Not ineffective — trial strategy reasonable and credited by trial court
Failure to object to foundation for admission of jailhouse phone calls	Seabrooks: calls lacked proper foundation and should have been excluded	State: investigator authenticated system, PINs, outgoing numbers, and voice ID; foundation was adequate	Not ineffective — evidence properly admitted; objection would have been meritless
Coercion not to testify	Seabrooks: counsel coerced him into not testifying	State/Trial ct: lengthy on-the-record colloquy where Seabrooks affirmed voluntary decision; counsel advised against testifying but left decision to client	Not ineffective — trial court credited voluntariness; counsel’s advice was permissible strategy
Other listed IAC claims (e.g., failure to interview witness, provide discovery)	Seabrooks: assorted allegations of counsel failures (listed without analysis)	State: many claims unpreserved or abandoned for lack of briefing and not raised below	Abandoned or not preserved; in any event, claims lacked merit

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel)
Slaton v. State, 303 Ga. 651 (2018) (applicant bears burden to prove both deficient performance and prejudice)
Henderson v. State, 304 Ga. 733 (2018) (one-sentence, uncited IAC claims may be deemed abandoned under Rule 22)
Gomez v. State, 301 Ga. 445 (2017) (declining to find IAC where counsel reasonably chose not to highlight a passing remark)
Smith v. State, 300 Ga. 538 (2017) (standards for admitting computer-controlled audio like jail calls under the Evidence Code)
Jones v. State, 299 Ga. 40 (2016) (authentication sufficient for recorded jail calls)
Lupoe v. State, 300 Ga. 233 (2016) (counsel not ineffective for failing to object to admissible evidence)
Thornton v. State, 292 Ga. 796 (2013) (counsel not ineffective for advising client not to testify when decision is voluntary)