Teasley v. State
293 Ga. 758
| Ga. | 2013Background
- Three brothers (Emory, Christopher, Tyrone Teasley) were indicted for the October 29, 2005 shootings that killed James Riden and wounded Markez Jones; all three were tried together and convicted; this opinion affirms Emory’s convictions.
- Eyewitnesses placed the Teasleys at the pool hall (the Big H), described an altercation, saw Tyrone fire, and testified that the victims were unarmed; Chris drove the brothers away after shots and Tyrone discarded the gun.
- Both Chris and Emory gave post-arrest statements to police; each statement was redacted to omit references to co-defendants and admitted at trial; Chris did not testify at trial.
- Emory’s recorded statement claimed the victims drew and fired guns; other evidence and testimony (including Tyrone’s) contradicted that account and implicated Emory in directing shots.
- Emory sought suppression of his statement as obtained in custody without Miranda warnings; the trial court held he was not in custody during the interview and admitted the statement after a Jackson–Deno hearing.
- Emory also alleged ineffective assistance for trial counsel’s failure to call certain witnesses (Lieutenant Curott and Emory himself) at the suppression hearing; the court rejected deficiency and prejudice claims. Judgment affirmed.
Issues
| Issue | Emory's Argument | State's Argument | Held |
|---|---|---|---|
| Admission of co-defendant Chris’s redacted statement (Bruton claim) | Admission violated Sixth Amendment because the jury could infer Emory was implicated despite limiting instruction | Statement was redacted and limiting instruction was given; no Bruton violation | No violation: redaction + instruction sufficient; any prosecutor misstatement was forfeited and harmless |
| Prosecutor’s opening remark about inconsistent statements | Remark improperly urged jury to use Chris’s statement against Emory, undermining limiting instruction | No contemporaneous objection; remark was brief and non-specific; harmless error | Procedurally barred; harmless beyond a reasonable doubt in any event |
| Admissibility of Emory’s statement (Miranda/custody) | Emory was effectively in custody at the station and should have received Miranda warnings; statement should be suppressed | At time of interview Emory was not formally arrested or restrained to degree of arrest; reasonable person would not feel in custody | Trial court’s custody finding upheld; statement admissible |
| Ineffective assistance for failing to call witnesses at suppression hearing | Counsel unreasonably failed to call Lt. Curott and Emory and failed to advise Emory of right to testify; caused prejudice | Curott’s trial testimony and detective’s hearing testimony were before the court; additional testimony would not have changed result; no prejudice | Strickland not satisfied: no deficient performance shown and no reasonable probability of different outcome |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
- Bruton v. United States, 391 U.S. 123 (Confrontation Clause limits on non-testifying co-defendant confessions)
- Gray v. Maryland, 523 U.S. 185 (redaction must remove any reference to defendant’s existence to avoid Bruton error)
- Miranda v. Arizona, 384 U.S. 436 (Miranda custody-and-interrogation warnings requirement)
- Jackson v. Denno, 378 U.S. 368 (pretrial hearing on voluntariness/admissibility of confessions)
- Strickland v. Washington, 466 U.S. 668 (ineffective-assistance-of-counsel standard)