Simpkins v. State, 303 Ga. 752

Late night June 2013: Simpkins and several men affiliated with the “MFG” gang gathered near Club Apollo and agreed to attack members of a rival group, the “Wrens Boys.”
Simpkins rode in the rear driver-side seat of a car driven by co-defendant Rajonte McGruder; shots were fired at the Wrens Boys; Kenneth Quarterman Jr. was killed and another victim was wounded.
At a joint trial with McGruder, the jury convicted Simpkins of malice murder and related offenses; Simpkins received life plus consecutive prison terms.
On appeal Simpkins claimed trial counsel was ineffective for failing to object under Bruton to McGruder’s out-of-court statements (as relayed by a GBI agent) that, he contends, inculpated Simpkins.
The State presented McGruder’s statements through testimony by Agent Sarah Lue; those statements did not name Simpkins and became accusatory only when linked with other evidence identifying Simpkins as the shooter.
The trial court denied a motion for new trial; the Georgia Supreme Court reviewed the ineffective-assistance claim and affirmed the convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for not objecting to co-defendant McGruder’s statements as a Bruton violation	Simpkins: counsel should have objected because McGruder’s statements, as introduced, implicated Simpkins in the shooting and violated his Confrontation Clause rights	State/counsel: the statements were not facially incriminating, only became incriminating when connected with other evidence; counsel identified and sought appropriate redactions and no limiting instruction could cure a true Bruton problem	Court: No deficient performance — statements did not directly inculpate Simpkins on their face (Bruton not triggered); counsel’s conduct was reasonable; conviction affirmed

Bruton v. United States, 391 U.S. 123 (1958) (admission of a nontestifying co-defendant’s facially incriminating confession can violate the Confrontation Clause)
Richardson v. Marsh, 481 U.S. 200 (1987) (Bruton limited; non–name-identifying confessions often permissible)
Gray v. Maryland, 523 U.S. 185 (1998) (redactions that leave obvious blanks can implicate Bruton)
Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance of counsel)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence)
Moss v. State, 275 Ga. 96 (2001) (Bruton not violated where statement becomes incriminating only when linked with other evidence)
Thomas v. State, 300 Ga. 433 (2017) (Georgia framing of Bruton: excludes only statements that directly inculpate when standing alone)