3. Appellant next contends that the Court should evaluate cumulative prejudice, in accordance with State v. Lane , 308 Ga. 10, 838 S.E.2d 808 (2020), to examine the combined prejudicial effect of the "errors" alleged in the above two enumerations. See id. at 17 (1), 838 S.E.2d 808 (holding that appellate courts must "consider collectively the prejudicial effect, if any, of trial court errors, along with the prejudice caused by any deficient performance of counsel" – at least where those errors and deficiencies involve evidentiary issues).

An ineffective assistance of trial counsel claim must be considered with a view to the impact of any deficiencies in trial counsel's conduct on the trial's outcome as a whole, and thus our discussion below addresses each of the individual claims of ineffective assistance in the appeal and the cross-appeal while always keeping in mind how the individual claims might relate to one another or build on one another. See State v. Lane , 308 Ga. 10, 15-16 (1), 838 S.E.2d 808 (2020) ("The United States Supreme Court has told us explicitly that we must consider prejudice collectively in the context of ineffective assistance of counsel and Brady[] prosecutorial misconduct claims."). Brady v. Maryland , 373 U. S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963)

Appellant Carl Lamont Jones was convicted of felony murder and other crimes in connection with the April 7, 2015 shooting death of John Lee Jones. On appeal, Appellant contends that the trial court erred in denying his motion to suppress certain evidence collected from his back yard; that the trial court abused its discretion in failing to properly question and remove a juror who disclosed mid-trial that she went to school with one of the witnesses; that the trial court erred by refusing to permit Appellant to cross-examine a witness about her pending criminal charge; and that Appellant is entitled to a new trial due to the cumulative effect of multiple errors at trial under State v. Lane , 308 Ga. 10, 838 S.E.2d 808 (2020). For the reasons that follow, we affirm Appellant's convictions.

We review this evidentiary ruling by the trial court for an abuse of discretion. See State v. Lane , 308 Ga. 10, 20, 838 S.E.2d 808 (2020). At the time of Marlon's statements, he and Appellant had not yet been charged with crimes related to Cole's murder, and it may be that their alleged conspiracy to commit those crimes was still in its concealment phase.

An ineffective assistance of trial counsel claim must be considered with a view to the impact of any deficiencies in trial counsel's conduct on the trial's outcome as a whole, and thus our discussion below addresses each of the individual claims of ineffective assistance in the appeal and the cross-appeal while always keeping in mind how the individual claims might relate to one another or build on one another. See State v. Lane, 308 Ga. 10, 15-16 (1) (838 S.E.2d 808) (2020) ("The United States Supreme Court has told us explicitly that we must consider prejudice collectively in the context of ineffective assistance of counsel and Brady prosecutorial misconduct claims.").

Obviously, however, a disregard of the essential and substantial provisions of the statute will have the effect of vitiating the array. Al-Amin v. State , 278 Ga. 74, 80 (7), 597 S.E.2d 332 (2004) (citation and punctuation omitted), overruled on other grounds by State v. Lane , 308 Ga. 10, 23, (Appendix), 838 S.E.2d 808 (2020). In State v. Towns , we recognized "that this Court never before ha[d] attempted to articulate a standard that clearly marks the line between the provisions of jury selection statutes that are ‘essential and substantial’ and those that are not."

Slaughter admits that the statements in question would likely have eventually been introduced eventually to the jury as impeachment evidence. See State v. Lane , 308 Ga. 10, 21 (4), 838 S.E.2d 808 (2020) ("[A] harmless error does not require reversal of a conviction."). 5. Slaughter finally asserts that, under Lane , 308 Ga. 10, 838 S.E.2d 808, the cumulative effect of the trial counsel's ineffective assistance entitles him to a new trial.

However, more recently this Court has treated the two tests as being distinct, particularly when any difference between them might matter. See Harris v. State , 313 Ga. 872, 882 (4), 874 S.E.2d 73 (2022) (addressing the two standards side-by-side); State v. Lane , 308 Ga. 10, 21-22 (4), 838 S.E.2d 808 (2020) (noting the two different standards but noting that "in most cases a difference in the standards will not make a difference in the result"); Boatright v. State , 289 Ga. 597, 601-602 (7), 713 S.E.2d 829 (2011) (addressing the two standards side-by-side); Felton v. State , 283 Ga. 242, 246-247 (2) (d), 657 S.E.2d 850 (2008) (addressing the two standards side-by-side). See also Hilliard v. State , 226 Ga. App. 478, 482 (1), 487 S.E.2d 81 (1997) (describing the two standards as "similar").

2014) ("While one of the officers interrogating appellant did tell him he could go home, such statements in context did not constitute a hope of benefit because no one promised appellant that he would not be charged with a crime or that he would receive reduced charges, sentencing or punishment if he made incriminating statements."), overruled on other grounds by State v. Lane, 308 Ga. 10 (838 S.E.2d 808) (2020).

Finally, Kirkland asserts that he is entitled to a new trial because of the cumulative prejudicial effect of the trial court’s errors. See State v. Lane, 308 Ga. 10, 14 (1), 838 S.E.2d 808 (2020) (holding that "Georgia courts considering whether a criminal defendant is entitled to a new trial should consider collectively the prejudicial effect of trial court errors"). To establish cumulative error, however, an appellant must show that "at least two errors were committed in the course of the trial."