[12, 13] "The prejudicial effect of evidence is ‘unfair’ if it has the capacity to lure the factfinder into declaring guilt on a ground different from proof specific to the offense charged, or an undue tendency to suggest decision on an improper basis, commonly, though not necessarily, an emotional one." Carter v. State, 317 Ga. 689, 694, 895 S.E.2d 295 (2023) (cleaned up). And we look at the evidence in the light most favorable to its admission, "maximizing its probative value and minimizing its undue prejudicial impact."

[15, 16] Establishing plain error requires an appellant "to show, among other things, that the alleged error likely affected the outcome of his trial." Carter v. State, 317 Ga. 689, 691 (1), 895 S.E.2d 295 (2023). And establishing ineffective assistance of counsel requires an appellant "to show not only that the failure of his trial counsel to object was professionally deficient, but also that[,] but for such deficient performance, there is a reasonable probability that the result of the trial would have been different."

We have said that "[t]he standard for relevance is a liberal one, and relevant evidence is admissible even if it has only slight probative value." Carter v. State, 317 Ga. 689, 693 (2) (895 S.E.2d 295) (2023) (citation and punctuation omitted; emphasis supplied). See also, e.g., Siders v. State, 320 Ga. 367, 374 (3) (a) (907 S.E.2d 645) (2024) ("The standard for relevant evidence is a liberal one, and such evidence is generally admissible even if it has only slight probative value.")

Westbrook v. State, 308 Ga. 92, 101 (5) (a) (839 S.E.2d 620) (2020) (citations and punctuation omitted). See also Carter v. State, 317 Ga. 689, 694-695 (2) (895 S.E.2d 295) (2023) (holding that admitting evidence was not a "clear and obvious [error] beyond reasonable dispute" where there was a "reasonable argument" based on the record that the evidence was admissible (punctuation omitted)).

For all of these reasons, Watkins has not met his heavy burden of showing that the trial court clearly and obviously erred. See, e.g., id. (concluding that the trial court did not plainly err in admitting testimony because the appellant did not meet his burden of showing that it "was a clear error that was not open to reasonable dispute"); Carter v. State, 317 Ga. 689, 694 (2) (895 S.E.2d 295) (2023) (concluding that the trial court did not plainly err in admitting a document showing proof of the appellant's incarceration because any error was not "clear and obvious beyond reasonable dispute"). This plain-error claim therefore fails.

To establish plain error, Richardson "must point to a legal error that was not affirmatively waived, was clear and obvious beyond reasonable dispute, affected his substantial rights, and seriously affected the fairness, integrity, or public reputation of judicial proceedings." Carter v. State, 317 Ga. 689, 693 (2), 895 S.E.2d 295 (2023) (citations and punctuation omitted). However, if Richardson fails to show just one of these elements, we need not analyze the rest.

Because Hassan has not shown that allowing the testimony at issue was a clear error that was not open to reasonable dispute, his claim of plain error fails. See Carter v. State, 317 Ga. 689, 694 (2), 895 S.E.2d 295 (2023); Stafford v. State, 312 Ga. 811, 820 (3) (b), 865 S.E.2d 116 (2021); Strother v. State, 305 Ga. 838, 848 (4) (d), 828 S.E.2d 327 (2019). [4] 2. Hassan contends that the trial court erred in failing to instruct the jury regarding the State’s "heightened burden of proof’ under OCGA § 24-14-6, which provides: "To warrant a conviction on circumstantial evidence, the proved facts shall not only be consistent with the hypothesis of guilt, but shall exclude every other reasonable hypothesis save that of the guilt of the accused."

The records themselves did not show that Jennings was stealing from Perrin. But ,see Carter v. State, 317 Ga. 689, 694 (2), 895 S.E.2d 295 (2023) ("The prejudicial effect of evidence is unfair if it has the capacity to lure the factfinder into declaring guilt on a ground different from proof specific to the offense charged, or an undue tendency to suggest decision on an improper basis, commonly, though not necessarily, an emotional one." (citation and punctuation omitted)).

(Citation and punctuation omitted.) Carter v. State, 317 Ga. 689, 693 (2), 895 S.E.2d 295 (2023). And, in order "to establish that the error affected his substantial rights, he must demonstrate that it caused him harm, meaning that the outcome of the trial court proceedings was likely affected."

(citation omitted)).Carterv. State, 317 Ga. 689, 693 (2), 895 S.E.2d 295 (2023) (punctuation omitted). [11] The failure to make a meritless objection is, of course, not ineffective assistance of counsel.