Truett v. State, 311 Ga. 313

Christopher Truett was indicted for malice murder, felony murder, aggravated battery, and first-degree child cruelty after two-year-old Wyatt Pruitt died from extensive blunt-force and asphyxial injuries in February 2014; Truett was the only adult present when Wyatt was found unresponsive.
Autopsy concluded multiple deliberate blunt-force abdominal injuries (including an 8 cm liver laceration) caused death; head and neck injuries indicated squeezing/strangulation; injuries inconsistent with a stair fall or CPR.
Truett fled the scene, disabled his phone, gave inconsistent accounts to police, attempted to remove material from his hands, and Wyatt’s DNA was found under Truett’s fingernail.
At trial Truett testified and presented seven character witnesses who testified to his positive reputation around children and peacefulness; trial court limited defense questioning to reputation/opinion and barred certain specific-instance and trust-with-child questions.
Truett moved for a new trial arguing erroneous exclusion of character evidence; the trial court denied the motion, finding any error harmless because the proffered testimony was cumulative and the guilt evidence was strong.
The Supreme Court of Georgia affirmed, holding any exclusion of the disputed testimony was harmless beyond a reasonable probability of affecting the verdict.

Issue	Plaintiff's Argument (Truett)	Defendant's Argument (State)	Held
Whether trial court erred by excluding defense character evidence (asking witnesses if they'd be comfortable with Truett around their children and specific instances of good character)	Exclusion prevented testimony permitted by OCGA § 24-4-405(b) and undermined his defense that he would not harm a child	Trial court properly limited testimony to reputation/opinion; further specifics were cumulative and beyond permissible scope	No reversible error; exclusion (if any) was harmless because testimony offered at trial was largely cumulative and evidence of guilt was very strong

Davenport v. State, 309 Ga. 385 (2020) (discusses the Court’s practice regarding sua sponte sufficiency-of-the-evidence review)
Strong v. State, 309 Ga. 295 (2020) (discusses application of OCGA §§ 24-4-404(a) and 24-4-405(b) on character evidence)
Williams v. State, 302 Ga. 147 (2017) (articulates nonconstitutional harmless-error standard for excluded evidence)
Keller v. State, 308 Ga. 492 (2020) (harmless-error where exclusion was cumulative and guilt evidence was strong)
Mitchell v. State, 293 Ga. 1 (2013) (exclusion of evidence harmless when similar proof was admitted through other testimony)