Slaton v. State, 303 Ga. 651

Background

On April 10, 2012, Justin Klaffka was killed; William Slaton (appellant), Matthew Pike, and Daniel Slaton were indicted for murder and related offenses; Daniel pled guilty and testified for the State.
Appellant and Pike were tried together; both were convicted of malice murder and appellant received life without parole.
Appellant moved for a new trial alleging numerous errors, principally ineffective assistance of counsel on multiple fronts; the trial court denied the motion.
On appeal, the Georgia Supreme Court reviewed sufficiency of the evidence and a series of ineffective-assistance and evidentiary claims.
The Court affirmed: evidence was sufficient; trial counsel’s performance was not deficient or did not prejudice appellant on the asserted grounds.

Issues

Issue	Plaintiff's Argument (Slaton)	Defendant's Argument (State)	Held
Sufficiency of evidence for malice murder	Evidence did not prove Slaton’s guilt beyond a reasonable doubt	Evidence (including co‑defendant testimony and corroborating witnesses) established motive, acts, and statements showing guilt	Affirmed: evidence sufficient under Jackson v. Virginia
Counsel failed to explain plea consequences (parole possibility and life‑without‑parole risk)	Trial counsel did not tell Slaton that the plea allowed parole and that conviction would trigger mandatory life without parole	Counsel and the trial court warned Slaton about plea/parole consequences; record supports counsel’s explanation	Denied: no deficient performance; factual finding not clearly erroneous
Failure to move for severance (antagonistic defenses / evidence admissible only against Pike)	Joint trial prejudiced Slaton because co‑defendants’ defenses and some evidence favored incriminating Pike	Counsel moved to sever; record shows common evidence and ability to present alibi and blame Pike; strategy choices reasonable	Denied: severance motion made; no prejudice shown; no ineffective assistance
Admission of evidence about April 8 Fluellen armed robbery	Evidence of the prior robbery was prejudicial and should have been excluded	Prior‑act evidence admissible under three‑part test and relevant to motive and intent; trial court properly admitted it	Denied: trial court did not abuse discretion; counsel properly objected at trial
Prosecutor’s reference to robbery in opening statement	Improper reference before foundation; prejudicial	Pretrial ruling allowed admission; prosecutor may preview expected admissible evidence; no contemporaneous objection	Waived by failure to object; meritless if preserved; counsel not ineffective for failing to make a meritless objection
Admission of certified indictment showing Daniel’s plea (including tampering counts nolle prossed as to Slaton)	Indictment admission prejudiced Slaton by suggesting charges against him	Indictment was used in cross‑examination; trial court removed tampering counts from jury materials and gave limiting instruction	Plain‑error review: no substantial rights affected; no prejudice; counsel not ineffective for failing to object
Counsel’s trial presentation errors (leading questions, playing wrong video clips, not admitting second Mitchell interview, failing limiting instruction)	Multiple tactical errors undermined defense and prejudiced Slaton	Many choices were reasonable strategy; objections would likely fail or were waived; record lacked proffer to show omitted material was exculpatory; jury instructed to disregard improper clips	Denied: no deficient performance or no prejudice shown; strategic decisions within range of reasonable representation
Hearsay and evidentiary objections (Daniel’s statement about probation, alibi witness handling)	Counsel should have objected to hearsay or preserved alibi corroboration	Statements were admitted non‑hearsay (effect on hearers); alibi witness testified inconsistently and record lacks proof counsel’s procedural steps would have changed outcome	Denied: objections meritless or no prejudice shown

Key Cases Cited

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
Strickland v. Washington, 466 U.S. 668 (ineffective assistance framework)
Wiggins v. State, 295 Ga. 684 (ineffectiveness burden and standard)
Pike v. State, 302 Ga. 795 (companion opinion addressing same facts/evidence)
Capps v. State, 300 Ga. 6 (presumption counsel’s conduct reasonable; strategic decisions)
Jenkins v. State, 303 Ga. 314 (deference to trial court factual findings on ineffectiveness)
Faust v. State, 302 Ga. 211 (no ineffectiveness for failing to make meritless objections)
Poole v. State, 291 Ga. 848 (limiting instruction and prejudice analysis)
Gates v. State, 298 Ga. 324 (statements admitted for effect on hearer, not hearsay)
Williams v. State, 302 Ga. 474 (need for proffer to show omitted evidence would be favorable)