Simpson v. State, 289 Ga. 685

Appellant Gregory Simpson killed Patricia Simmons by stabbing; he had a history of violent, threatening conduct toward Simmons in the months before her death.
Simmons had lived with Simpson and later with a friend; Simpson continued to threaten and assault Simmons, including knife-point incidents and attempts at rape, leading to fear and several police calls.
On the night of the murder, Simmons' body was found; she had been stabbed over 100 times and bled to death.
Police questioned Simpson; he agreed to go to the station if they could inspect his clothes, which contained a blood stain later linked to Simmons.
Simpson’s clothes were seized after arrest and kept in a brown paper bag with no chain of custody; DNA from the clothing matched Simmons and the crime scene.
Trial evidence also included Simpson’s prior violent conduct and a contemporaneous description of a man matching him banging on Simmons’ door within an hour of her death.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence legally sufficient to sustain all convictions?	Simpson	State asserts sufficient evidence	Yes; convictions upheld under Jackson v. Virginia.
Was there probable cause to arrest Simpson and seize his clothes without a warrant?	Simpson	State argues officer knowledge and corroborating facts established probable cause	Yes; officers on duty had knowledge of facts supporting probable cause; seizure proper.
Did forcing Simpson to surrender his clothes violate his self-incrimination rights?	Simpson	State constitutional authority to seize in custody permits search; no compelled self-incrimination	No; Georgia extends protection, but police could seize as incident to lawful arrest; no Fifth Amendment violation.
Was trial counsels’ failure to object to the chain-of-custody or to obtain DNA/ bite-mark experts ineffective assistance?	Simpson	Counsel’s strategy reasonable; lack of prejudice	No reversible error; strategic choices were reasonable and there was strong trial evidence of guilt.
Was counsel ineffective for not impeaching Quinn on additional points?	Simpson	Counsel adequately impeached; additional points were not necessary	No; presenting some impeachment evidence sufficed under Strickland.

Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court, 1979) (Evidentiary sufficiency standard for conviction)
Devenpeck v. Alford, 543 U.S. 146 (U.S. Supreme Court, 2004) (Probable cause assessment focuses on reasonable belief of guilt)
Maryland v. Pringle, 540 U.S. 366 (U.S. Supreme Court, 2003) (Totality of circumstances for reasonable grounds of belief)
Brown v. State, 262 Ga. 728 (Ga. 1993) (Collective knowledge vs. individual arresting officer knowledge)
Eberhart v. State, 257 Ga. 600 (Ga. 1987) (Search/seizure of items in custody without warrant post-arrest)
Arizona v. Gant, 556 U.S. 332 (U.S. 2009) (Car searches incident to arrest limitations)
Creamer v. State, 229 Ga. 511 (Ga. 1972) (Right not to perform incriminating acts extends to self-incrimination protections)
Day v. State, 63 Ga. 667 (Ga. 1879) (Georgian rule on compelled physical acts relating to incrimination)
Brown v. State, 307 Ga.App. 797 (Ga. App. 2011) (Collective knowledge considerations (appellate discussion))