Watkins v. State, 289 Ga. 359

On April 21, 2006, Watkins and co-defendants attempted to rob the China Wok restaurant on Delk Road at night while armed.
Watkins and Williams entered the kitchen; a cook Yan Sing Ku was shot and killed, another cook Parilla was wounded but survived.
After the robbery, Watkins expressed to the group that he believed he had killed someone and threatened violence if anyone talked about it.
Brown’s mother learned of the shooting from Brown’s calls; law enforcement were alerted, leading to police involvement and statements from Watkins and Williams.
Watkins admitted entering the restaurant with a .25 caliber handgun but claimed he left after hearing gunshots; trial evidence sufficed to support convictions.
Watkins challenged the convictions on multiple grounds, including peremptory strike use, suppression, and ineffective assistance of counsel, which the Supreme Court addressed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Watkins argues evidence fails to prove malice murder and related counts beyond a reasonable doubt.	State contends the jury could reasonably credit the witnesses and evidence establishing intent and actions.	Evidence was sufficient to sustain guilt beyond a reasonable doubt.
Gender-based peremptory strikes	Watkins asserts discriminatory use of seven of eight strikes against women.	State argues no prima facie case of gender discrimination established given panel composition and strikes.	Trial court did not abuse discretion; no prima facie case of gender-based discrimination shown.
Race-based peremptory strikes (Batson)	Watkins claims race-based strikes violated Batson.	State provided race-neutral reasons; court found reasons not pretextual.	Batson challenge denied; race-neutral explanations upheld.
Ineffective assistance of trial counsel	Watkins claims multiple failures by trial counsel prejudiced outcome.	State contends strategic decisions were reasonable and not prejudicial.	Claims rejected; no reasonable probability of different outcome shown.
Suppression and Miranda waiver	Watkins argues waiver was not knowing and voluntary due to intoxication and impairment.	Detective testimony and waiver evidence support knowing and voluntary waiver.	Trial court did not err; waiver found knowing and voluntary.

Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court, 1979) (sufficiency standard; jury credibility resolved by jury)
J.E.B. v. Alabama, 511 U.S. 127 (U.S. Supreme Court, 1994) (peremptory challenges and gender discrimination)
Batson v. Kentucky, 476 U.S. 79 (U.S. Supreme Court, 1986) (race-based peremptory strikes prohibited)
Ledford v. State, 289 Ga. 70 (2011) (criteria for prima facie Batson showing; race-neutral explanations)
Martinez, 621 F.3d 101 (2d Cir. 2010) (abuse of discretion standard for Batson rulings)
Krause v. State, 286 Ga. 745 (2010) (Jackson-Denno hearing and voluntariness considerations)
Philmore v. State, 263 Ga. 67 (1993) (voluntary statements despite intoxication considerations)
Johnson v. State, 286 Ga. 787 (2010) (reasonable strategic decisions defense impact on ineffective assistance claims)
Vergara v. State, 283 Ga. 175 (2008) (totality-of-circumstances standard for Miranda waivers)
Allen v. State, 277 Ga. 502 (2004) (trial strategy and prejudice standard)