Jeffery Douglas v. State

CourtCourt of Appeals of Georgia
DecidedJune 27, 2014
DocketA14A0649
StatusPublished

This text of Jeffery Douglas v. State (Jeffery Douglas v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jeffery Douglas v. State, (Ga. Ct. App. 2014).

Opinion

THIRD DIVISION BARNES, P. J., BOGGS and BRANCH, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules/

June 27, 2014

In the Court of Appeals of Georgia A14A0649. DOUGLAS v. THE STATE.

BARNES, Presiding Judge.

A jury convicted Jeffery Douglas of three counts of armed robbery, two counts

of aggravated assault, possession of a gun during the commission of a crime,

carjacking, and misdemeanor obstruction of an officer. On appeal, he contends that

the evidence was insufficient to sustain his convictions and that his trial counsel was

ineffective for failing to investigate the criminal records of the three victims and

impeaching them with that evidence on cross-examination. While we find the

evidence sufficient for retrial, we agree that counsel’s actions fell below an objective

standard of reasonableness, and that a reasonable probability exists that if counsel had

been effective Douglas would have been acquitted of all but the misdemeanor

obstruction charge.1 Accordingly, we reverse the armed robbery, aggravated assault,

1 Douglas does not argue that his counsel’s ineffectiveness led to a reasonable probability that he would have been acquitted of the charge of obstructing “a law enforcement officer in the lawful discharge of his official duties, by running after being told to stop,” nor does he argue that the evidence on this charge was use of a gun during the commission of a crime, and carjacking convictions and

remand for further proceedings.

1. Douglas contends that the evidence was not sufficient to authorize the jury

to find him guilty beyond a reasonable doubt because the evidence against him was

circumstantial and failed to exclude any other reasonable hypothesis except his guilt.

The appellate court reviews the evidence in the light most favorable to the verdict, giving deference to the jury’s determination on the proper weight and credibility to be given the evidence. It is for the jury to determine the credibility of the witnesses and to resolve any conflicts or inconsistencies in the evidence.

(Citations and punctuation omitted.) Farris v. State, 290 Ga. 323, 324 (1) (720 SE2d

604) (2012).

Viewed in that light, the evidence at trial showed that the three victims were

close friends and met at Mosely Park one late afternoon. They sat on a bench and

were “drinking, kicking, . . . [and] saying stuff” when two men walked up, both with

guns raised. The robbers took the victims’ cell phones and threw them away, then

ordered the victims to lie face down on the ground. Victim One testified that the

shorter robber — whom he identified at trial as Douglas — took his wallet, car keys,

insufficient. Accordingly, that conviction is affirmed.

2 and $500 cash, and the taller robber took $600 from Victim Two and $25 from Victim

Three. The two robbers then drove off in the Victim One’s car, but as soon as they

pulled into the street they were hit by an oncoming car. The robbers jumped out of the

car and began to run.

Victims One and Two began to chase the robbers, who turned and shot at the

victims and then kept running. Victim Two got into his car and began to chase the

robbers through the neighborhood as they ran between houses. The robbers eventually

split up and ran into the woods. A witness to the crime also began to chase the

robbers because he was very familiar with the neighborhood, but when they split off

the witness lost sight of both robbers for a time.

Meanwhile, an off-duty officer in his personal vehicle drove by Victim One’s

wrecked car in the middle of the road and called 911 after one of the victims said he

been robbed and shot at. The officer helped establish a perimeter and left after

another officer responded to the 911 call. The responding officer talked to one of the

victims, who described the robbers as two African American men, one in a “white

gray-colored shirt and blue jeans with somewhat of a low haircut” and the other

wearing “possibly a blue shirt with a fisherman’s hat.” The officer radioed the

description to other officers in the area who had responded to the call.

3 A patrol officer heard the description of the robbers and began patrolling the

area. He got out of his car to walk through the neighborhood and saw an African

American man with a white grayish shirt and blue jeans walking across a back yard.

That man was Douglas. Douglas began to walk “a lot faster” when he saw the officer.

The witness from the park saw Douglas and told the officer, “That’s him, that’s him,”

meaning one of the robbers. The officer ran back behind a house and found Douglas

squatting down underneath a deck and “burrowing into his pocket looking like he was

looking for something.”

The officer drew his gun, identified himself, and told Douglas to show his

hands, but instead Douglas crawled out from under the deck and began to run away

despite the officer’s order to stop. Douglas jumped two fences but the officer caught

up with him when he tripped and placed him under arrest. Douglas had $305 balled

up in his pocket but no cell phones or gun. No money, cell phones, or weapons were

found along the pathway of the chase.

The arresting officer placed Douglas in the back of another officer’s patrol car,

and testified that the three victims walked up to the car and said, “Oh, yeah, that’s

him; that’s him; that’s him right there.” The other responding officer also testified

that the victims identified Douglas when he was brought back to the park in the back

4 of a patrol car. Regardless of where the patrol car was located when the victims

identified Douglas as the robber, the record is clear that he was under arrest in the

back of a police car when they did so. Further, the witness who chased the robbers

also identified Douglas as one of the robbers after his arrest.

When we review a challenge to the sufficiency of the evidence, “the relevant

question is whether, after viewing the evidence in the light most favorable to the

prosecution, any rational trier of fact could have found the essential elements of the

crime beyond a reasonable doubt.” (Emphasis omitted.) Jackson v. Virginia, 443 U.

S. 307, 319 (III) (B) (99 SCt 2781, 61 LE2d 560) (1979). The evidence as outlined

above is sufficient to authorize the jury’s verdict on the charges of three armed

robberies, two aggravated assaults, possession of a firearm during the commission of

a crime, carjacking, and misdemeanor obstruction of an officer. See Range v. State,

289 Ga. App. 727, 729 (2) (658 SE2d 245) (2008); Dunn v. State, 262 Ga. App. 643,

645 (1) (586 SE2d 352) (2003).

2. Douglas also contends that his trial counsel was ineffective for failing to

investigate the victims’ criminal histories even though the defense theory was that the

victims misidentified Douglas as one of the robbers.

5 Ineffective assistance is a “deficient performance” by counsel resulting in

“actual prejudice.” Head v. Hill, 277 Ga. 255, 266 (VI) (587 SE2d 613) (2003). We

strongly presume that trial counsel “rendered adequate assistance and made all

significant decisions in the exercise of reasonable professional judgment,” and

counsel’s performance is evaluated without reference to hindsight. Strickland v.

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