State v. Lane, 308 Ga. 10

Defendant Antiwan Lane was convicted of malice murder and related charges after Kevin Stallworth admitted he was the shooter and testified that Lane procured a murder-for-hire; Stallworth was the State’s key witness.
Prosecution introduced corroborating evidence that was largely hearsay (e.g., testimony from Brittany Thompson and statements by Detective Delima); much of that hearsay went unobjected to at trial.
Cell‑phone records and other circumstantial evidence showed phone contacts and movements linking Stallworth and a number associated with Lane, but did not directly prove Lane solicited the killing.
Trial counsel failed to cross‑examine Detective Delima about a known inconsistency (Davis’s denial) and failed to object to hearsay/bolstering testimony by the detective.
The trial court admitted Thompson’s testimony recounting Stallworth’s out‑of‑court statements (over objection), later found that admission improper, and granted Lane a new trial.
The State appealed; the Georgia Supreme Court (1) overruled prior Georgia precedent disallowing cumulative‑error review in criminal new‑trial contexts, (2) found counsel deficient in at least two respects and the trial court erred in admitting Thompson’s hearsay, and (3) affirmed the grant of a new trial based on cumulative prejudice.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Lane)	Held
Whether Georgia should permit cumulative‑error review of trial‑court errors and counsel deficiencies	Continue to reject cumulative aggregation; errors considered separately	Review errors cumulatively because combined prejudice can deny fair trial	Court overruled prior rule and adopted cumulative review for evidentiary errors and counsel deficiencies
Whether counsel was ineffective for not cross‑examining Detective Delima about his false testimony re: Davis	Failure to cross‑examine was strategic or harmless	Failure was objectively unreasonable; left false testimony unchallenged	Counsel’s failure was deficient performance; trial court’s finding upheld
Whether counsel was ineffective for not objecting to hearsay/bolstering by Detective Delima	Any error was harmless or strategic choice	Failure to object was unreasonable and permitted inadmissible, corroborative hearsay to stand	Court held failure to object was deficient performance
Whether Thompson’s testimony recounting Stallworth’s statements was admissible as conspiracy‑in‑furtherance or prior consistent statement	Testimony admissible as statements in furtherance of a conspiracy	Statements were not in furtherance; were hearsay and improperly bolstering	Trial court did not abuse discretion in excluding those statements; their admission was error

Strickland v. Washington, 466 U.S. 668 (establishes two‑prong ineffective assistance standard)
Kyles v. Whitley, 514 U.S. 419 (Brady materiality assessed collectively)
Chambers v. Mississippi, 410 U.S. 284 (consider cumulative effect of trial errors on fairness of trial)
Berger v. United States, 295 U.S. 78 (probable cumulative effect of prosecutorial misconduct)
Bannister v. State, 306 Ga. 289 (harmless‑error framework in Georgia)
Williams v. State, 302 Ga. 147 (role of other evidence in harmless‑error analysis)
United States v. Adams, 722 F.3d 788 (6th Cir.) (collective prejudice of evidentiary errors may require new trial)
United States v. Al‑Moayad, 545 F.3d 139 (2d Cir.) (vacatur based on cumulative evidentiary and other errors)
United States v. Hands, 184 F.3d 1322 (11th Cir.) (consider cumulative prejudice from trial errors)