(Citation and punctuation omitted.) Williams v. State, 304 Ga.App. 592, 593(1), 696 S.E.2d 512 (2010). See also Davenport v. State, 316 Ga.App. 234, 237(1)(b), 729 S.E.2d 442 (2012).

]" Carter v. State, 265 Ga. App. 44, 50 (4) (c), fn. 25 ( 593 SE2d 69) (2004). See also Fogarty v. State, 270 Ga. 609, 613 ( 513 SE2d 493) (1999); Goss v. State, 305 Ga. App. 497, 499 (2) ( 699 SE2d 819) (2010); Williams v. State, 304 Ga. App. 592, 595 (4) ( 696 SE2d 512) (2010); Henderson v. State, 303 Ga. App. 898, 900 (1) (b) ( 695 SE2d 334) (2010); Ellison v. State, 296 Ga. App. 752, 756 (2) (c) ( 675 SE2d 613) (2009); Port v. State, 295 Ga. App. 109, 112 (2) (a) ( 671 SE2d 200) (2008); Grier v. State, 276 Ga. App. 655, 662 (4) ( 624 SE2d 149) (2005); Caylor v. State, 255 Ga. App. 362, 363 ( 566 SE2d 33) (2002); Bradford v. State, 221 Ga. App. 232, 235 (3) ( 471 SE2d 248) (1996). Regarding the second requirement in Strickland, in order to establish prejudice, "a defendant [must] show `a reasonable probability sufficient to undermine confidence in the outcome that, but for counsel's alleged unprofessional errors, the result of the proceeding would have been different.' [Cits.

This line of questioning established an ample foundation for introduction of the prior inconsistent statement. See Williams v. State, 304 Ga.App. 592, 594(3), 696 S.E.2d 512 (2010); Gooch v. State, 289 Ga.App. 74, 76(2), 656 S.E.2d 214 (2007). Although OCGA § 24–9–83 provides that written contradictory statements that are in existence shall be shown or read to the witness, there is no similar language requiring [audio recordings of] statements to be [played for] the witness prior to their use for impeachment purposes.

Moreover, Wright has not shown that the jury was confused by this additional instruction because it set out a correct statement of the law regarding force in rape cases. Frady v. State , 359 Ga. App. 255, 258-259 (4), 857 S.E.2d 260 (2021) ; Williams v. State , 304 Ga. App. 592, 593-594 (1), 696 S.E.2d 512 (2010). Thus, we conclude that Wright has not shown that the trial court erred in instructing the jury on the element of force.

In light of the record before us, we conclude that the DNA evidence of McEady's identity rendered harmless any error in the admission of E. A.’s hearsay identification. See, e.g., Sanchious v. State , 351 Ga. App. 611, 616 (1) (b), 831 S.E.2d 843 (2019) (holding that the admission of a forensic report was harmless in light of properly admitted testimony regarding the contents of the report); Williams v. State , 304 Ga. App. 592, 595 (3), 696 S.E.2d 512 (2010) (holding that admission of hearsay evidence — that the victim was pregnant with the defendant's child — was harmless because there was properly admitted DNA evidence showing the same). See also OCGA § 24-8-802 ("Hearsay shall not be admissible except as provided by this article; provided, however, that if a party does not properly object to hearsay, the objection shall be deemed waived, and the hearsay evidence shall be legal evidence and admissible.").

Force may be inferred from intimidation arising from the familial relationship and may be proved by direct or circumstantial evidence. Davenport v. State , 316 Ga. App. 234, 237 (1) (b), 729 S.E.2d 442 (2012) (force element of rape was shown where defendant had sexually assaulted his stepdaughter repeatedly when she was a child); Williams v. State , 304 Ga. App. 592, 593 (1), 696 S.E.2d 512 (2010). Oates was 49 years old at the time of the crimes, was the live-in boyfriend of T. H.’s mother, entered 13-year-old T. H.’s bedroom when she was in bed and no one else was home, and performed sex acts upon her. That same day, T. H. phoned her grandmother and told her that Oates had raped her and had previously touched her inappropriately, and she went to live with her grandmother.

Therefore, there could be no harm in the admission of this evidence. See Obeginski v. State, 313 Ga.App. 567, 570(2), 722 S.E.2d 162 (2012) (failure to object to evidence that was cumulative of evidence presented in forensic interview did not amount to ineffective assistance); Williams v. State, 304 Ga.App. 592, 595(3), 696 S.E.2d 512 (2010) (hearsay harmless when statements are cumulative of other admissible evidence). (c) Maurer argues that trial counsel failed to object to the State's improper impeachment of V.G.'s brother B.G. after B.G. repeatedly testified that he did not want to answer questions.

” White v. State, 268 Ga. 28, 33(6), 486 S.E.2d 338 (1997). See also Williams v. State, 304 Ga.App. 592, 595(3), 696 S.E.2d 512 (2010). The trial court did not err in allowing the State to question a police officer in rebuttal about inconsistent statements from Thompson or his fiancée.

(Citation and punctuation omitted.) Williams v. State, 304 Ga.App. 592, 593(1), 696 S.E.2d 512 (2010); House v. State, 236 Ga.App. 405, 409(1), 512 S.E.2d 287 (1999) (evidence was sufficient to establish force where the father repeatedly sexually assaulted a child, the child's outcries to her mother were ignored, and the father warned the child not to tell anyone about his abuse). Notwithstanding Davenport's claims that the victim consented by “accepting” money for sex, the victim stated that she never wanted to have sex with Davenport, she was relieved to have been removed from the home, and she tried to keep Davenport out of her room by locking the door when she was forced to return to the home.

He therefore has failed to meet his burden of showing harm. See Williams v. State, 304 Ga.App. 592, 595(4), 696 S.E.2d 512 (2010). (b) The father also contends that counsel stipulated to an additional ground of deprivation not alleged in the original deprivation petition.