Styles v. State
329 Ga. App. 143
Ga. Ct. App.2014Background
- Styles was tried for burglary and four counts of armed robbery arising from a home invasion where gunpoint were used to take property from four victims.
- Lamar Jones, co-defendant, testified for the state after negotiating a guilty plea; Jones described the plan and execution of the heist.
- The defense argued Styles did not participate in Jones’s planning and that Jones alone committed the crimes; Styles admitted entry but claimed Jones acted independently.
- Evidence showed Styles helped facilitate entry by re-opening a door and remaining in the residence while the gunman executed the robbery; the gunman left before police arrived.
- Counts included four armed robberies; Styles was also charged with firearm possession during the felonies, but those counts were acquitted.
- Styles challenged the sufficiency of the evidence, requested a lesser-included offense instruction on robbery by intimidation, and claimed ineffective assistance of counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Styles contends the evidence fails to prove burglary without authority and armed robberies beyond a reasonable doubt. | Styles argues the record shows lack of participation and no gun by Styles, so convictions are unsupported. | Evidence supports each essential element; convictions affirmed. |
| Lesser included offense instruction on robbery by intimidation | Styles seeks a robbery by intimidation instruction as a lesser included offense. | State asserts no evidence of robbery by intimidation; instruction not warranted. | No plain error; instruction not required where evidence shows completed armed robberies with no intimidation element. |
| Effect of acquittals on firearm-possession counts | Not applicable; argues jury would have punished him differently if given intimidation instruction. | Acquittals on firearm counts do not imply prejudice to higher offenses or require lesser-included instruction. | Not plain error; speculation about jury’s reasoning rejected. |
| Ineffective assistance of counsel | Trial counsel failed to request robbery-by-intimidation instruction and failed to call a witness who could impeach Jones. | Counsel made a strategic choice to pursue an all-or-nothing defense; lack of witness was not deficient. | No deficient performance; strategy was reasonable; failure to call the witness not shown to be prejudicial. |
| Additional ineffective-assistance challenges | Counsel allegedly failed to retrieve 911 recordings and investigate callers. | No evidence established what those recordings or investigations would have shown or their relevance. | No prejudice shown; claim rejected. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (requires viewing evidence in light most favorable to the prosecution to sustain a conviction)
- Thompson v. State, 271 Ga. 105 (Ga. 1999) (reverses burglary where entry was not shown to be without authority)
- State v. Kelly, Georgia Supreme Court decision (four-prong plain error test) (Ga. 2011) (establishes four-prong plain-error standard for omitted jury instruction)
- Edwards v. State, 264 Ga. 131 (Ga. 1994) (limits on plain-error review and jury instruction standards)
- Crowder v. State, 294 Ga. 167 (Ga. 2013) (preserves that appellate review respects jury credibility determinations)
- Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (establishes performance-prejudice standard for ineffective-assistance claims)