Watts v. State, 308 Ga. 455

Defendant Laurence Frantie Watts was retried in 2010 for the 2003 shooting death of Brent Ogletree after the trial court granted a new trial based on an instructional error; he was again convicted of malice murder and related firearm offenses and sentenced to life plus five years.
Multiple eyewitnesses placed Watts (aka “Tay”) at the scene firing multiple shots; Ogletree (aka “Santa Claus”) was unarmed and died from a chest gunshot wound.
Watts admitted shooting but asserted self-defense, claiming prior threats, warnings that someone had a hit on him, and that he reasonably believed Ogletree was reaching for a gun.
At retrial, key witness Christopher Champion’s testimony differed in some wording from his 2004 testimony (including that Watts “emptied the pistol” and “frowned” at Champion); Watts’ counsel did not impeach Champion with the prior testimony on that variation.
Watts moved for a new trial alleging ineffective assistance of trial counsel for failing to impeach Champion; the trial court denied relief after an evidentiary hearing, and the Georgia Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for not impeaching Champion on variations between his 2004 and 2010 testimony	Watts: counsel should have impeached Champion to undermine Champion’s 2010 version (e.g., "emptied the pistol") and strengthen Watts’ self-defense claim	State: counsel’s decision was a reasonable trial strategy to avoid highlighting the shooting and to attack bias/recollection instead	Court: Counsel’s choice was objectively reasonable trial strategy; Watts failed to show deficient performance or a reasonable probability of a different outcome; claim denied

Strickland v. Washington, 466 U.S. 668 (establishes deficient performance and prejudice standard for ineffective assistance)
Jackson v. Virginia, 443 U.S. 307 (standard for legal sufficiency review of convictions)
Romer v. State, 293 Ga. 339 (performance must be judged objectively under prevailing norms)
McNair v. State, 296 Ga. 181 (trial tactics/strategy rarely establish ineffective assistance)
Davis v. State, 306 Ga. 140 (decisions whether and how to impeach are tactical)
Shaw v. State, 292 Ga. 871 (credibility and justification are jury questions)
Smith v. State, 300 Ga. 532 (presumption that counsel’s choices are strategic)