State v. Crapp, 317 Ga. App. 744

Crapp was convicted of armed robbery and kidnapping of Tyhesha Strawder, and entering her automobile with intent to commit kidnapping.
The trial court granted Crapp a new trial, finding defense counsel failed to corroborate Crapp’s defense with evidence he possessed.
The state appeals, arguing Crapp did receive effective assistance of counsel.
The trial court concluded trial counsel’s performance was deficient and likely affected the outcome.
Crapp’s defense centered on alleged prior incidents with a co-defendant and witnesses, which counsel failed to corroborate with available documents.
The appellate court applied Strickland v. Washington to determine whether deficient performance and prejudice merited reversal and affirmed the trial court’s grant of a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Effective assistance of counsel as issue	Crapp	Crapp	Defendant’s claim determined on deficiency and prejudice

Head v. Carr, 273 Ga. 613 (Ga. 2001) (mixed question of law and fact; independent legal principles applied on factual findings.)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes deficient performance and prejudice standard.)
Gibson v. State, 280 Ga. App. 435 (Ga. App. 2006) (counsel’s failure to introduce corroborating records can be deficient performance.)
Hart v. Gomez, 174 F.3d 1067 (9th Cir. 1999) (documents corroborating testimony; failure to introduce constitutes deficient performance.)
Zant v. Moon, 264 Ga. 93 (Ga. 1994) (in close cases, defense mistakes take greater significance.)
Richardson v. State, 189 Ga. App. 113 (Ga. App. 1988) (presence of corroborating evidence could affect outcome.)