Wood v. The State

Summary

The Supreme Court of Georgia affirmed Bobby Wood, Jr.'s convictions for felony murder and aggravated assault arising from the shooting death of Aaron Skinner. The court held that any error in restricting cross-examination concerning the victim's arrest was harmless, and that Wood failed to show a due-process violation from post-trial denial of access to physical evidence. The court also rejected Wood's ineffective-assistance and cumulative-error claims.

Holdings

1. Even assuming the trial court erred by preventing Wood from cross-examining Major King about Skinner's arrest for criminal trespass, the error was harmless because it was highly probable that it did not contribute to the verdict.
2. The trial court did not abuse its discretion by denying Wood's request to permit a post-trial ballistics expert to examine the firearm, ammunition, shell casings, and bullets because Wood failed to show that favorable testing results would create a reasonable probability of a different trial result.
3. Wood failed to establish ineffective assistance because, even assuming counsel performed deficiently by not objecting to the State's redirect examination about Skinner's lack of convictions, Wood did not show a reasonable probability that the result would have been different.
4. Wood failed to establish cumulative error because the assumed evidentiary error and assumed counsel deficiency, considered together with the entire record, did not deprive him of a fundamentally fair trial.

Questions Presented

1. Whether the trial court abused its discretion by preventing Wood from cross-examining the State's ballistics expert about Skinner's arrest for criminal trespass.
2. Whether the trial court violated due process by denying Wood post-trial access to physical evidence for examination by a retained ballistics expert in support of an ineffective-assistance claim.
3. Whether trial counsel was ineffective for failing to object to the State's redirect examination of its expert about Skinner's lack of criminal convictions.
4. Whether the cumulative effect of the alleged trial-court error and counsel deficiency deprived Wood of a fundamentally fair trial.

Disposition

affirmed