Simpkins v. State
814 S.E.2d 289
Ga.2018Background
- In June 2013, Damien Simpkins and others associated with a gang confronted a group called the "Wrens Boys." Simpkins sat in the rear driver-side seat of a car and shots were fired; Kenneth Quarterman, Jr. was killed and Lewis Brown III was wounded.
- Simpkins and codefendant Rajonte McGruder were jointly tried; the State presented testimony including Agent Sarah Lue recounting McGruder's post-arrest statements to police.
- McGruder's statements described others being "told" to act and referred to an unnamed person who fired from the back seat, but the statements did not expressly name Simpkins.
- Simpkins was convicted of malice murder and related offenses and sentenced to life plus consecutive terms; he filed a motion for new trial and appealed.
- On appeal Simpkins argued his trial counsel was ineffective for failing to object to introduction of McGruder's statements as a Bruton violation (a Confrontation Clause claim that a non-testifying codefendant's confession improperly incriminated him).
- The Georgia Supreme Court reviewed Strickland ineffective-assistance standards and Bruton-line Confrontation Clause doctrine and affirmed, finding no deficient performance or Bruton violation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial counsel was ineffective for not objecting to McGruder's non-testifying statements as a Bruton violation | Simpkins: McGruder's statements inculpated him and counsel should have objected; failing to do so was professionally deficient and prejudicial | State: McGruder's statements did not facially incriminate Simpkins; they only became inculpatory when linked with other evidence, so no Bruton violation and counsel's conduct was reasonable | Held: No deficiency or prejudice—statements were not facially incriminating under Bruton; counsel reasonably addressed redaction concerns and the record supports conviction |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance two-prong standard)
- Bruton v. United States, 391 U.S. 123 (Confrontation Clause bars admission of a non-testifying codefendant's facially incriminating confession)
- Richardson v. Marsh, 481 U.S. 200 (Bruton is narrow; confessions not naming defendant change the calculus)
- Gray v. Maryland, 523 U.S. 185 (redactions that plainly indicate deletion can trigger Bruton)
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)