Delaney v. State, 304 Ga. 256

Summary

The Georgia Supreme Court affirmed Raven Marie Delaney’s convictions for malice murder and related offenses arising from the shooting deaths of two men. The court held that trial counsel was not ineffective for failing to object to testimony regarding a co-defendant’s polygraph examinations because counsel used the testimony to support the defense theory that the co-defendant was the actual murderer.

Holdings

1. The evidence was sufficient for a rational trier of fact to find beyond a reasonable doubt that Delaney was guilty of the charged offenses.
2. Counsel was not constitutionally ineffective because the decision not to object to the polygraph testimony was not unreasonable under the circumstances and therefore did not constitute deficient performance.

Questions Presented

1. Whether trial counsel rendered ineffective assistance by failing to object when the State elicited testimony that prosecution witness Josh Rood had passed a polygraph examination.
2. Whether the evidence was legally sufficient to support Delaney's convictions, notwithstanding her failure to challenge sufficiency on appeal.

Disposition

affirmed