Valentine v. State, 293 Ga. 533

Valentine spent the night of Oct. 9–10, 2010 with Alfred Harris and Judith Miracle; later Harris was found dead from blunt-force head trauma.
Miracle testified Valentine threatened her, prevented her from leaving, escorted her out of the apartment, and Valentine later burned clothes and fled when confronted.
Investigators found Harris’s blood on a toilet-tank cover and elsewhere in the apartment; Valentine’s blood was on a bedroom sheet.
Valentine made multiple post-crime statements suggesting consciousness of guilt (e.g., telling relatives he thought he had killed someone) and fled when a neighbor threatened to call police.
Indicted for multiple offenses, Valentine was convicted of malice murder and kidnapping (lesser included), sentenced to life without parole plus 20 years; felony murder vacated by operation of law; other counts merged.

Issue	Plaintiff's Argument (Valentine)	Defendant's Argument (State)	Held
Sufficiency of evidence for convictions	Evidence insufficient to prove guilt beyond a reasonable doubt	Physical evidence, eyewitness testimony, blood evidence, and incriminating statements establish guilt	Affirmed: evidence sufficient under Jackson v. Virginia standard
State failed to produce written expert blood-spatter report and trial court’s short postponement denied adequate prep time	Trial court’s limited postponement gave counsel insufficient time; witness testimony should be excluded	Delay remedied by postponing testimony and allowing defense interview; no bad faith by State, no prejudice shown	Affirmed: defendant waived by not requesting more time; exclusion unnecessary absent bad faith and prejudice
Ineffective assistance for failure to obtain psychological evaluation (and failure to present intoxication expert)	Counsel was deficient for not seeking/preparing mental-health or intoxication experts, which could have aided defense	No evidence an evaluation would have produced favorable proof; voluntary intoxication not a defense; counsel’s decision not objectively shown to be prejudicial	Affirmed: Strickland prejudice not shown; no reasonable probability result would differ

Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency-of-evidence standard)
Scott v. State, 290 Ga. 883 (application of sufficiency standard)
Heywood v. State, 292 Ga. 771 (discovery duty to produce expert report)
Norris v. State, 289 Ga. 154 (remedy of interview/continuance for discovery violation)
Moss v. State, 275 Ga. 96 (waiver by failing to request continuance)
Strickland v. Washington, 466 U.S. 668 (ineffective-assistance standard)
Kimmelman v. Morrison, 477 U.S. 365 (counsel competence in investigative choices)
Hambrick v. Brannen, 289 Ga. 682 (need more than speculation to show prejudice from lack of evaluation)
Arnold v. State, 292 Ga. 268 (defendant must show evaluation would change outcome)
Jennings v. State, 282 Ga. 679 (burden to show mental condition warranting investigation)
Martin v. Barrett, 279 Ga. 593 (importance of evidentiary proof of diagnosis/treatment)
Guyton v. State, 281 Ga. 789 (prejudice requirement for ineffective assistance claim)
Chance v. State, 291 Ga. 241 (sanctions for discovery violations require bad faith and prejudice)
Leppla v. State, 277 Ga. App. 804 (voluntary intoxication not a defense; counsel not ineffective for failing to present such a defense)