Pollard v. State

321 Ga. 671
CourtSupreme Court of Georgia
DecidedMay 28, 2025
DocketS25A0658
StatusPublished
Cited by1 cases

This text of 321 Ga. 671 (Pollard v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pollard v. State, 321 Ga. 671 (Ga. 2025).

Opinion

321 Ga. 671 FINAL COPY

S25A0658. POLLARD v. THE STATE.

MCMILLIAN, Justice.

Ray Eugene Pollard was convicted of malice murder in relation

to the shooting death of Jonathon McAfee.1 On appeal, Pollard

argues that trial counsel rendered constitutionally ineffective

1 The shooting occurred on October 3, 2020. On November 6, 2020, a

Baldwin County grand jury indicted Pollard, charging him with malice murder (Count 1), felony murder (Count 2), aggravated assault (Count 3), and interference with government property (Count 4). On December 6, 2021, the trial court entered an order of nolle prosequi for Count 4. At a trial from December 6 through 8, 2021, a jury found Pollard guilty of all remaining counts. On December 8, 2021, the trial court sentenced Pollard to serve life in prison without the possibility of parole for Count 1. Count 2 was vacated by operation of law, and the trial court purported to merge the conviction on Count 3 with Count 2 for sentencing purposes. However, the conviction on Count 3 actually merged with Count 1 because the felony murder count was vacated. See Miller v. State, 309 Ga. 549, 552 (3) (847 SE2d 344) (2020) (“When there is no evidence to suggest the occurrence of an aggravated assault independent of the act which caused the victim’s death, as in this case, a jury’s guilty verdict on the aggravated assault merges as a matter of fact with the malice murder verdict for sentencing purposes.” (cleaned up)). Pollard filed a timely motion for new trial on January 6, 2022, which was later amended through new counsel on December 28, 2023. Following a hearing on January 3, 2024, the trial court denied the motion for new trial, as amended, on February 2, 2024. Pollard filed a timely notice of appeal on February 27, 2024, which was amended on February 29, 2024. The case was docketed to the April 2025 term of this Court and submitted for a decision on the briefs. assistance by failing to object to the admission of cell-site location

information (“CSLI”) obtained without a search warrant. Even

assuming that trial counsel was deficient in failing to object to this

evidence, Pollard has not shown that a reasonable probability exists

that, but for counsel’s error, the outcome of the trial would have been

different, so we affirm.

1. The evidence presented at trial showed the following. Pollard

and Wendy Pence were in a relationship for “[a]bout nine and a half

years” before Pence ended the relationship on August 21, 2020. That

night, she left Pollard’s house in Acworth and drove to McAfee’s

house in Milledgeville. The next morning, on August 22, Pence

awoke at 7:00 a.m. to Pollard “banging on the door, screaming

[Pence’s] name for [her] to come outside . . . [a]nd honking the horn.”

McAfee’s mother, who lived nearby, heard “somebody sitting on

their horn, just constant . . . just screaming and banging” and saw

“somebody beating on [McAfee’s] door,” so she called 9-1-1. An officer

arrived at the scene and made contact with Pollard, who had a

loaded 9mm pistol with him. Pollard was “removed [ ] from the

2 property” and told that he “wasn’t allowed back.” At the time,

Pollard was driving a “white SUV,” and the officer’s body camera

footage from that morning showed that his vehicle had intact

taillights and what appears to be an undamaged tailpipe and

muffler. Pollard continued to contact Pence “[a] lot” after this

incident, and Pence eventually “[b]locked him” on Facebook and

changed her phone number to prevent further communication.

Around 10:00 p.m. on October 3, 2020, McAfee was leaving his

job for the night. A co-worker testified that, as they were locking up,

he saw a “light-color,” “SUV-type vehicle” drive through the parking

lot at a “high rate of speed,” coming “up around [McAfee’s] truck”

and then exiting the lot. This was captured by the business’s

surveillance camera.

Pence testified that she was making dinner at McAfee’s house

that night and heard McAfee’s truck pull into the yard. Pence then

heard “a gunshot” and ran outside to find McAfee “[o]n the ground

on the passenger side of his truck,” bleeding from his stomach.

McAfee was “screaming, ‘Baby, Baby, call 911, call 911.’” Dispatch

3 received Pence’s 9-1-1 call at 10:26 p.m. McAfee’s mother testified

that she also heard a “very loud gunshot” and McAfee screaming, so

she went over to McAfee’s house. When she arrived, Pence was on

the phone with 9-1-1 and McAfee was on the ground surrounded by

“[a] lot of blood.” McAfee was taken to the hospital by emergency

services where he was ultimately pronounced dead from a single

gunshot wound to his “left waistline area.”

An officer who observed the scene on the night of the shooting

testified that the shot “would have come from the roadway or from

the direction of the roadway, because [McAfee] was hit in the lower

abdomen[;] where he was found laying, he could not have been shot

from behind him, because of the truck, so he was either facing the

roadway or facing to his left toward the roadway.” The State’s expert

in forensic pathology testified that “the shooter was at least five to

six feet away” because there was no “gunpowder or smoke deposited

on [McAfee’s] skin” or clothing. The State’s firearms and

ammunition expert testified that the bullet recovered from McAfee’s

body “came from a [.]30 caliber rifle.”

4 Pence immediately expressed concern to law enforcement that

Pollard might have been responsible for the shooting. She told

officers that, to her knowledge, Pollard drove a white 2004 Chevrolet

Trailblazer and owned a .30-30 rifle. Pence also provided them with

Pollard’s cell phone number.

At 11:35 p.m., Acworth law enforcement visited Pollard’s house

to see if his vehicle was present, but they were unable to locate it.

The supervisor of the criminal investigations division then

instructed one of his investigators “to seek a court order to get

[Pollard’s] phone records.” He received “approximately 48 hours

worth of phone records” — which covered the hours both prior to and

after the incident and included location data from Pollard’s phone.

The records showed that, at 8:43 p.m. on October 3, Pollard was “on

I-20 east of Atlanta, [near] Moreland Avenue.”2 There was no further

location data collected until 1:56 a.m. on October 4,3 at which point

2 It was noted during trial that Pollard’s Acworth house is about “[f]orty

minutes” north of Atlanta. 3 An officer testified that “[t]here’s basically four ways to stop [location

data] collection on a phone. . . . One is the phone goes dead, you turn the phone

5 Pollard was “at or very near his residence in Acworth.” Officers

checked Pollard’s house again for his vehicle at 4:30 a.m. on October

4, and the Trailblazer was present.4 At that time, an officer observed

that “one of the taillight lenses [on the vehicle] was busted.”

Beyond McAfee’s house is a cul-de-sac and a Department of

Transportation (“DOT”) fence that runs parallel to the nearby Fall

Line Freeway. As law enforcement searched the area, they “found

tire tracks leading from the cul-de-sac and ultimately through a

large fence” that led up to the freeway. The fence had “extensive

damage,” including a “very large opening that would have been

sufficiently wide for a vehicle to pass through.” Officers collected “a

large strand of wire” near the freeway that was “consistent with the

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321 Ga. 671, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pollard-v-state-ga-2025.