"This Court does not have to analyze all elements of the plain-error test where an appellant fails to establish one of them." Payne v. State, 314 Ga. 322, 325 (1), 877 S.E.2d 202 (2022). Here, Durden hinges his argument on an alleged violation of OCGA § 24-7-701 (a), which provides:
"Where accomplice testimony is the bedrock of the conviction, it may be likely that the jury convicted the defendant on the accomplice's testimony alone." Payne v. State , 314 Ga. 322, 326 (1), 877 S.E.2d 202 (2022) (citation and punctuation omitted). Here, the most incriminating evidence against Jackson did not come from Murphy—it came from Odom.
(Citations and punctuation omitted.) Payne v. State, 314 Ga. 322, 328-329 (3), 877 S.E.2d 202 (2022). "In reviewing a trial court’s determination regarding a claim of ineffective assistance of counsel, this court upholds the trial court’s factual findings unless they are clearly erroneous; we review a trial court’s legal conclusions de novo."
To the extent there is any ambiguity in the record about what parts of Tavarez's statement were played for the jury, that does not help Tavarez, who bears the burden of establishing that counsel was constitutionally ineffective. See Payne, 314 Ga. at 328-329 (3), 877 S.E.2d 202; see also Rodriguez v. State, 295 Ga. 362, 368 (2) (b) n.11, 761 S.E.2d 19 (2014) (any ambiguity in the record does not help the appellant, who bears the burden of showing error in the record on appeal).
Id. at 260-262, 824 S.E.2d 326. See also Payne v. State, 314 Ga. 322, 333-334, 877 S.E.2d 202 (2022) (rejecting claim that trial counsel was deficient in failing to investigate and present evidence that another person was the perpetrator, on the ground that proffered evidence was not relevant because it did not raise reasonable inference of appellant’s innocence); Goins v. State, 310 Ga. 199, 207-209, 850 S.E.2d 68 (2020) (applying reasonable-inference-of-innocence standard and laying out Rule-401 relevance standard in addressing whether proffered third-party-guilt was admissible).[8] Here, the testimony that Appellant sought to elicit from the fire investigator and other witnesses does not raise a reasonable inference of Appellant’s innocence.
"If [a defendant] fails to establish one of these two prongs, we need not examine the other." Payne v. State, 314 Ga. 322, 328 (3), 877 S.E.2d 202 (2022) (citation and punctuation omitted). "To show deficient performance, the defendant must demonstrate that counsel performed counsel’s duties in an objectively unreasonable way, considering all of the circumstances and in the light of prevailing professional norms."
We see no merit to this claim, [26-29] To prevail on his ineffectiveness of counsel claim, Velazquez must establish that his trial counsel’s representation was. "constitutionally deficient" and that "he was prejudiced by counsel’s deficient performance," Payne v. State, 314 Ga. 322, 328 (3), 877 S.E.2d 202 (2022), ’’meaning that but for counsels deficient performance, a reasonable probability exists that the outcome at trial would have been different." Fitts v. State, 312 Ga. 134, 139 (2), 859 S.E.2d 79 (2021) (citing Strickland v. Washington, 466 U.S. 668, 687 (III) 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984)).
6. Next, Henderson contends that there was not sufficient evidence to corroborate the testimony of Brandi Singleton, who he contends was an accomplice to the crimes. See OCGA § 24-14-8 (the testimony of a single witness is not sufficient to establish a fact when the witness is an accomplice); Payne v. State , 314 Ga. 322, 326 (1), 877 S.E.2d 202 (2022) ("[A] jury may not rely solely on an accomplice's testimony to find any fact necessary to sustain a defendant's felony conviction. Instead, the existence of any such fact must also be supported either by the testimony of an additional witness or by other, independent evidence that corroborates the accomplice's testimony.")
We need not analyze all four prongs because Williams has failed to establish that the trial court clearly or obviously erred by admitting the CSLI evidence. See Payne v. State , 314 Ga. 322, 325 (1), 877 S.E.2d 202 (2022) ("[We do] not have to analyze all elements of the plain-error test where an appellant fails to establish one of them."). "An error is plain if it is clear or obvious under current law.
"If [a defendant] fails to establish one of these two prongs, we need not examine the other." Payne v. State, 314 Ga. 322, 328 (3), 877 S.E.2d 202 (2022) (citation and punctuation omitted). "To show deficient performance, the defendant must demonstrate that counsel performed counsel’s duties in an objectively unreasonable way, considering all of the circumstances and in the light of prevailing professional norms."