Wallace v. State
296 Ga. 388
| Ga. | 2015Background
- May 3, 2007, Wallace planned to rob at a MARTA bus stop with Aikens and Eison; Moore was shot and died.
- Eison identified Wallace as the shooter; Wallace tattooed “unknown killer” and confessed to his girlfriend.
- Ballistics linked a 9mm gun found in Wallace’s bedroom to the murder; Wallace had purchased the gun.
- Wallace’s rap lyrics and related writings suggested targeting Black people; Eison pled guilty to aggravated assault.
- Wallace was convicted at a joint trial with Aikens; post-trial motions were denied; Wallace appealed; decision issued January 20, 2015.
- The court upheld all convictions, addressing sufficiency, evidentiary challenges, and ineffective assistance claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legal sufficiency of the evidence to sustain convictions | Wallace argues evidentiary gaps and credibility issues undermine guilt | State asserts sufficient evidence viewed in light favorable to verdict | Evidence sufficient to sustain verdict beyond reasonable doubt |
| Admission of Eison’s testimony about Wallace's character | Admission improperly placed Wallace’s character in issue | Testimony ambiguous and not admissible for character at issue; waiver noted | No reversible error; waiver and cautionary instruction supported admissibility |
| Voluntariness of custodial statement | Statements were involuntary due to Cocaine use and Miranda waiver issues | Detective testimony showed voluntary waiver and understanding of rights | Statement voluntary; Miranda waiver valid; admission proper |
| Ineffective assistance of counsel | Counsel deficient in several trial decisions; prejudice shown | No deficient performance or prejudice established; strategic choices justified | No ineffective assistance; claims rejected across subparts a–d |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for determining sufficiency of evidence)
- Bradley v. State, 292 Ga. 607 (Ga. 2013) (credibility and sufficiency considerations on appeal)
- Krause v. State, 286 Ga. 745 (Ga. 2010) (voluntariness and waiver under Miranda context)
- Philmore v. State, 263 Ga. 67 (Ga. 1993) (Miranda rights and voluntary waiver relevance)
- McIlwain v. State, 287 Ga. 115 (Ga. 2010) (ambiguity and relevance of evidence in trial)
- Cannon v. State, 288 Ga. 225 (Ga. 2010) (admissibility of evidence and related limits)
- Stephens v. State, 208 Ga. App. 620 (Ga. App. 1993) (racial references in opening statements and prejudice standards)
- Mize v. State, 269 Ga. 646 (Ga. 1998) (ineffective assistance framework and strategy considerations)
- Cupe v. State, 253 Ga. App. 851 (Ga. App. 2002) (trial strategy and foundation objections)
- Brown v. State, 307 Ga. App. 797 (Ga. App. 2011) (foundation objections and strategic decisions)
- Maxwell v. State, 290 Ga. 574 (Ga. 2012) (presumption of reasonable professional assistance)