Stroud v. State
301 Ga. 807
Ga.2017Background
- On Sept. 29, 2010 Wayne Jackson was found dead in his apartment from multiple stab wounds; blood spatter and signs of a struggle were present. A bloody kitchen knife and a second damaged knife were recovered.
- A palm print on the apartment doorknob matched Shamell A. Stroud’s right palm. Stroud fled, bought a bus ticket to New York, and was arrested in Norfolk, VA.
- Stroud gave a written statement and a recorded interview recounting a dispute and claiming self-defense; his trial testimony asserted self-defense but contained inconsistencies with his earlier statements and the medical evidence.
- Stroud testified at trial and admitted four prior felony theft convictions; the State impeached him with those convictions on cross-examination after a pretrial ruling allowing impeachment of the two most recent convictions and the State invoking character evidence after Stroud’s testimony.
- A jury convicted Stroud of malice murder and related counts; he was sentenced to life plus a consecutive five-year term for knife possession. Stroud appealed, arguing insufficiency of the evidence, erroneous admission of prior felonies, and ineffective assistance for failing to object to that evidence.
Issues
| Issue | Stroud’s Argument | State’s Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to support murder convictions | Evidence insufficient; self-defense claim supported by his account | Evidence (admissions, injuries, flight, inconsistencies) permits rational jury to reject self-defense | Affirmed — evidence sufficient to support convictions under Jackson v. Virginia standard |
| Admissibility of four prior felony theft convictions for impeachment | Admission was more prejudicial than probative; only limited impeachment should be allowed | Prior felonies admissible to impeach credibility when defendant testifies; court properly balanced and admitted the two most recent convictions and later allowed all four after defendant’s testimony | No reversible error — defendant acquiesced at trial; admission of two recent convictions was within discretion; any error as to older convictions was harmless |
| Waiver by counsel / Acquiescence to admission | Trial counsel’s concessions and statements did not waive right to appeal | Counsel affirmatively invited/admitted convictions and accepted court’s rulings at trial | Waiver/acquiescence prevents appellate challenge to admission of convictions |
| Ineffective assistance for failing to object to prior-conviction evidence | Counsel rendered constitutionally ineffective assistance by not objecting | No deficient performance as admitted evidence was admissible; even if deficient regarding older convictions, any error was harmless (no prejudice) | Claim fails — no deficient performance or no prejudice under Strickland |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence)
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard)
- Childs v. State, 287 Ga. 488 (impeachment with prior convictions; balancing test)
- Clay v. State, 290 Ga. 822 (factors for balancing probative value vs. prejudice)
- Lindsey v. State, 282 Ga. 447 (character evidence/"opening the door" context)
- Ridley v. State, 290 Ga. 798 (examples of when testimony opens door to prior-act evidence)
- Murray v. State, 295 Ga. 289 (jury credibility determinations; rejecting self-defense)
- Mote v. State, 277 Ga. 429 (harmless-error analysis in ineffective-assistance context)