Wells v. State, 307 Ga. 773

On September 19, 2013, Wells and four co-defendants planned a series of robberies: an attempted robbery/shooting of Sergio Mayfield (Mayfield survived) and a subsequent robbery that resulted in the fatal shooting of David Scott.
At the Scott incident Wells drove a stolen Ford F-150, helped position the vehicle, approached the victims while armed, and the group opened fire; Scott died from a gunshot wound to the head.
Co-defendant Dixon was arrested, waived rights, confessed, and helped police locate Wells; after a high-speed chase Wells was apprehended and items (ski masks, matching ammunition, and an AR-15) linking him to the crimes were recovered.
Wells was Mirandized, initialed and signed a waiver form, and gave a custodial interview admitting presence at the Mayfield shooting but denying involvement in the Scott killing.
A jury acquitted Wells of malice murder but convicted him of felony murder (predicated on aggravated assault) and multiple related offenses; he received life without parole on the felony-murder count plus additional concurrent and consecutive terms.
On appeal Wells argued (1) his custodial statements should have been suppressed because his Miranda waiver was not knowing, (2) admission of Dixon’s inculpatory statements violated his confrontation rights, and (3) trial counsel was ineffective for not moving to sever trials.

Issue	Plaintiff's Argument (Wells)	Defendant's Argument (State)	Held
Whether Wells knowingly and intelligently waived Miranda rights	Waiver was not fully understood; statements should be suppressed	Waiver was knowing and voluntary; Wells initialed and signed form and acknowledged understanding on video	Waiver was knowing and voluntary; suppression denied
Whether admission of accomplice Dixon’s inculpatory statements violated confrontation	Admission of Dixon’s out-of-court statements invaded confrontation rights	Dixon testified at trial and was subject to cross-examination	No violation—Dixon testified and was cross-examined
Whether trial counsel was ineffective for not moving to sever the trials	Joint trial with multiple defendants and events confused the jury; severance likely would have helped	Counsel made a reasonable strategic decision to keep co-defendants to shift blame; not objectively unreasonable	No ineffective assistance—strategy reasonable under Strickland

Jackson v. Virginia, 443 U.S. 307 (standard for reviewing legal sufficiency of the evidence)
Miranda v. Arizona, 384 U.S. 436 (Miranda warnings and custodial interrogation rules)
Berghuis v. Thompkins, 560 U.S. 370 (knowing and voluntary waiver inquiry)
Benton v. State, 302 Ga. 570 (Georgia on Miranda waiver and review standard)
State v. Clark, 301 Ga. 7 (totality-of-circumstances test for waiver)
Ardis v. State, 290 Ga. 58 (no confrontation violation when witness testifies and is cross-examined)
Strickland v. Washington, 466 U.S. 668 (two-prong ineffective-assistance standard)
Scott v. State, 290 Ga. 883 (Georgia application of Strickland)
Green v. State, 302 Ga. 816 (severance is a matter of trial strategy)
Lupoe v. State, 300 Ga. 233 (counsel’s strategic choices are unreasonable only if "no competent attorney" would choose them)