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Reid v. State

53 Citing cases

  1. Alexander v. State

    313 Ga. 521 (Ga. 2022)   Cited 8 times

    Thus, this case involves a criminal defendant who is seeking to challenge the closure of a courtroom solely through a Sixth Amendment claim of ineffective assistance of counsel under Strickland v. Washington , 466 U. S. 668, 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984). Relying on this Court's decision in Reid v. State , 286 Ga. 484, 488 (3) (b), 690 S.E.2d 177 (2010), the trial court and the Court of Appeals determined that the proper Strickland analysis requires a defendant in this posture to demonstrate actual prejudice to prevail and rejected Alexander's claim of ineffective assistance of counsel for failure to show any such prejudice. See Alexander v. State , 356 Ga. App. 392, 394-395 (2) (a), 847 S.E.2d 383 (2020).

  2. Morris v. State

    308 Ga. 520 (Ga. 2020)   Cited 11 times
    Finding that the charge given by the trial court was not error as it was an accurate statement of the law that was properly adjusted to the evidence and circumstances of the case, and defendant offered no evidence that the jury was confused or misled by this instruction

    However, "[t]he improper closing of a courtroom is a structural error requiring reversal only if the defendant properly objected at trial and raised the issue on direct appeal." Reid v. State , 286 Ga. 484, 488 (3) (c), 690 S.E.2d 177 (2010). Because the record reflects that Morris did not make a contemporaneous objection to the locking of the courtroom doors at trial, he has waived his right to appellate review of the trial court's action.

  3. Whatley v. State

    342 Ga. App. 796 (Ga. Ct. App. 2017)   Cited 7 times

    See Tolbert v. State, 321 Ga.App. 637 , 638 (1) (742 SE2d 152 ) (2013) (Even if the trial court improperly excluded the public from the courtroom, the defendant waived appellate review of such exclusion by not objecting to it at trial.); see also Reid v. State, 286 Ga. 484 , 487-488 (3) (c) (690 SE2d 177 ) (2010) (The improper closing of a courtroom is a structural error requiring automatic reversal of a conviction only if the defendant objected contemporaneously at trial and then raised the issue on direct appeal. “Indeed, to hold otherwise would encourage defense counsel to manipulate the justice system by intentionally failing to object in order to ensure an automatic reversal on appeal.”)

  4. Payne v. State

    314 Ga. 322 (Ga. 2022)   Cited 42 times
    Holding counsel was not deficient where appellant "offer[ed] no evidence in support of this claim other than suggesting that additional investigation could have led to exculpatory evidence"

    That leaves us nothing to review. See Pyatt v. State , 298 Ga. 742, 750 (5), 784 S.E.2d 759 (2016) ("[E]ven structural errors are capable of forfeiture."); Reid v. State , 286 Ga. 484, 488 (3) (c), 690 S.E.2d 177 (2010) ("The improper closing of a courtroom is a structural error requiring reversal only if the defendant properly objected at trial and raised the issue on direct appeal[.]"). 3. Payne also brings a host of claims of ineffective assistance of counsel.

  5. Freeman v. State

    760 S.E.2d 708 (Ga. Ct. App. 2014)   Cited 4 times
    Noting that a defendant should "not be allowed to induce an asserted error, sit silently hoping for acquittal, and obtain a new trial when that tactic fails" (citations and punctuation omitted)

    ” “[T]o hold otherwise would encourage defense counsel to manipulate the justice system by intentionally failing to object [to closure] in order to ensure an automatic reversal on appeal.” State v. Abernathy, 289 Ga. 603, 611(5), 715 S.E.2d 48 (2011) (punctuation omitted) (quoting Reid v. State, 286 Ga. 484, 487 (3)(c), 690 S.E.2d 177 (2010)). Freeman relies on R.W. Page Corp. v. Lumpkin, 249 Ga. 576, 292 S.E.2d 815 (1982), for the proposition that motions to close the courtroom must be in writing and meet other procedural safeguards.

  6. Walker v. State

    308 Ga. 33 (Ga. 2020)   Cited 17 times
    In Walker, the trial court ordered that spectators not be permitted to move in and out of the courtroom during closing arguments and the final jury charge.

    Nevertheless, even if counsel did act deficiently, Walker has failed to demonstrate prejudice. See Weaver v. Massachusetts , ––– U.S. –––– (IV), 137 S.Ct. 1899, 198 L.Ed.2d 420 (2017) ; Reid v. State , 286 Ga. 484 (3) (c), 690 S.E.2d 177 (2010). The transcript reflects that the public was permitted to be present in the courtroom during trial and that, during closing argument and the jury charge, individuals were present in the gallery.

  7. Purvis v. State

    288 Ga. 865 (Ga. 2011)   Cited 17 times
    Finding violation of right to public trial, but noting that brother, who was excluded from trial, “sought to attend the trial ‘just as a member of the general public,’ ” not as a witness

    We do not find it significant under the facts in this case that the trial court itself did not specifically order the exclusion of appellant's brother from the courtroom. Compare Presley v. Georgia, 558 U.S. ___ ( 130 SC 721, 722, 175 LE2d 675) (2010) (trial court ordered courtroom closed during voir dire, thus excluding defendant's uncle, who was the "lone courtroom observer"); Reid v. State, 286 Ga. 484 (3) (c) ( 690 SE2d 177) (2010) (trial court ordered courtroom temporarily closed during testimony of two witnesses). While the trial court may not have deliberately intended that members of the public be prevented from attending the trial, it was the trial court that deliberately decided to hold appellant's trial in the county jail courtroom.

  8. Alexander v. State

    356 Ga. App. 392 (Ga. Ct. App. 2020)   Cited 1 times

    (Citation and punctuation omitted.) Reid v. State , 286 Ga. 484, 485-486, 690 S.E.2d 177 (2010). Specifically, "[t]he improper closing of a courtroom is a structural error requiring reversal only if the defendant properly objected at trial and raised the issue on direct appeal[.]"

  9. Hillsman v. State

    341 Ga. App. 543 (Ga. Ct. App. 2017)   Cited 5 times
    Finding defendant acted with malicious intent where defendant acted intentionally and without justification or serious provocation

    Jessie v. State, 294 Ga. 375 , 377 (2) (a) (754 SE2d 46 ) (2014); accord Reid v. State, 286 Ga. 484 , 487 (3) (b) (690 SE2d 177 ) (2010). 17

  10. Freeman v. State

    A14A0610 (Ga. Ct. App. Jul. 16, 2014)

    " State v. Abernathy, 289 Ga. 603, 611 (5) (715 SE2d 48) (2011) (punctuation omitted) (quoting Reid v. State, 286 Ga. 484, 487 (3) (c) (690 SE2d 177) (2010). Freeman relies on R. W. Page Corp. v. Lumpkin, 249 Ga. 576 (292 SE2d 815) (1982), for the proposition that motions to close the courtroom must be in writing and meet other procedural safeguards.