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Woodv.State

CourtSupreme Court of Georgia
Docket No.S23A0637
DecidedJuly 5, 2023
Reporter316 Ga. 811, 890 S.E.2d 716 (2023)
JudgesColvin, J., delivered the opinion. All the Justices concurred.
Tags
CriminalMurderCross-Examination LimitsIneffective Assistance of CounselPost-Trial Evidence AccessCumulative ErrorSelf-Defense Claim
Case Summary

Bobby Wood was convicted of felony murder and aggravated assault, which merged into the murder conviction, after shooting Aaron Skinner near Wood’s home at night. Wood claimed self-defense, saying Skinner approached and pointed something at him; no weapon was found, Skinner never entered Wood’s fenced yard, and Wood acknowledged firing before he could tell whether Skinner had a gun. Ballistics evidence indicated the fatal shot ricocheted from the road as Skinner moved away. The jury acquitted Wood of malice murder, convicted him of felony murder, and he received life with the possibility of parole. On appeal, he challenged limits on cross-examining the State’s expert about Skinner’s prior trespass arrest, denial of posttrial access to physical evidence for defense testing, counsel’s failure to object to redirect testimony about Skinner’s lack of convictions, and cumulative error. The Supreme Court of Georgia held any evidentiary error harmless given the strong evidence against self-defense, found no due-process entitlement to testing without a showing it could establish ineffective-assistance prejudice, and rejected the counsel and cumulative-error claims for lack of prejudice. It affirmed; all Justices concurred.

Opinion

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