Geiger v. State

Summary

The Supreme Court of Georgia affirmed Tomorris Geiger’s convictions and sentences arising from the murders, robberies, kidnappings, and vehicle hijackings involving Dewayne and John Bacon. The court held that the evidence was sufficient, similar-transactions evidence was properly admitted, denial of a continuance was not an abuse of discretion, and claims concerning shackling and other character evidence were either meritless or waived. The court also rejected Geiger’s ineffective-assistance claims.

Holdings

1. The evidence was sufficient to enable a rational trier of fact to find Geiger guilty beyond a reasonable doubt of the offenses for which he was convicted.
2. The trial court did not err by admitting evidence of four similar transactions because the State established a proper purpose, sufficient evidence that Geiger committed the independent acts, and a sufficient connection or similarity between those acts and the charged crimes.
3. The trial court did not abuse its discretion by denying Geiger’s second motion for a continuance.
4. The trial court did not err in denying Geiger’s request for a new jury panel based on his brief exposure in leg irons, and his challenge to testimony about prior incarceration and attempts to evade police custody was waived because he did not object at trial.
5. Geiger failed to establish ineffective assistance because he did not show deficient performance and prejudice under Strickland.

Questions Presented

1. Whether the evidence was sufficient to support Geiger’s convictions.
2. Whether the trial court properly admitted evidence of four similar transactions.
3. Whether the trial court abused its discretion by denying Geiger’s second request for a continuance to independently test a shell casing and secure an additional witness.
4. Whether the trial court erred by permitting Geiger to be briefly seen in shackles and by admitting references to his prior incarceration and attempts to evade police custody.
5. Whether trial counsel provided ineffective assistance by failing to call Latoya Brewton, independently test the shell casing, and object to allegedly improper character evidence.

Disposition

affirmed