Woods v. State

CourtSupreme Court of Georgia
DecidedAugust 26, 2025
DocketS25A0508
StatusPublished

This text of Woods v. State (Woods 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
Woods v. State, (Ga. 2025).

Opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.

In the Supreme Court of Georgia

Decided: August 26, 2025

S25A0508. WOODS v. THE STATE.

ELLINGTON, Justice.

A Bibb County jury found Christopher Leon Woods guilty of

murder and other crimes in connection with the July 2021 shooting

death of Freddie Lee Battle. 1 Woods contends that his trial counsel

was ineffective for failing to properly advise him of his right to

testify in his defense at trial. For the reasons explained below, we

1 The crimes occurred on July 30, 2021. On October 8, 2021, a Bibb County grand jury indicted Woods for the crimes of malice murder (Count 1); felony murder predicated on the offense of possession of a firearm by a convicted felon (Count 2); and possession of a firearm by a convicted felon (Count 3). During a jury trial that began on April 18, 2023, the jury found Woods guilty on all counts. The trial court sentenced Woods to life in prison on Count 1, merged Count 3 into Count 2, and then vacated Count 2. (We express no opinion as to whether Count 3 was properly merged and note that this Court generally declines to exercise its discretion to correct any merger errors that benefit the defendant when the State has not raised the error in a cross-appeal. See Dixon v. State, 302 Ga. 691, 696-97. Woods filed a timely motion for new trial on May 22, 2023, which he twice amended. After a hearing held on August 13, 2024, the trial court denied the amended motion for new trial on August 26, 2024. Woods filed a timely notice of appeal on September 18, 2024. The case was thereafter docketed in this Court to the April 2025 term and submitted for a decision on the briefs. see no merit to this contention and affirm.

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

July 30, 2021, Woods called 911 and reported that he had shot his

roommate and friend, Battle. A sergeant with the Bibb County

Sheriff’s Office, who was wearing a bodycam at the time, responded

to Woods’s Bibb County home. When the sergeant arrived, he saw a

man, whom he later identified as Woods, standing in the front yard,

drinking liquor, and smoking a cigarette. The sergeant drew his

service weapon and ordered Woods to lie on the ground. Woods

complied, after he finished a shot of liquor.

As the sergeant handcuffed Woods, Woods offered, unsolicited,

that he had been drinking and that he “killed the motherf**ker.”

The sergeant asked Woods if he had any weapons on him, and Woods

admitted that he had knives. After disarming Woods, the sergeant

took him to the patrol car. On the way to the patrol car, Woods said

that he had been wanting to “kill his a** for two years.” When the

paramedics arrived, Woods told them: “He’s laying on the floor

dead.” The sergeant responded, “He’s dead?” Woods stated: “Yeah,

2 he’s dead, I shot him, I killed him, and I wanted to kill him too.”

After he sat in the patrol car, Woods made additional

unprompted statements. He said that he and Battle had argued, he

was fed up with Battle “putting his hands on him,” Battle had made

threats to him in the past, and he could not take it anymore. The

State played the sergeant’s body camera video of the encounter for

the jury.

On cross-examination, and after having his memory refreshed

with parts of his body camera video, the sergeant also testified that

Woods told him that he and Battle liked to drink and hunt raccoons

together; that, although they were friends and roommates, they

argued often; that Battle had knocked Woods down several times on

the evening of the shooting; that Battle had put his finger in Woods’

face; and that Battle had hit Woods in the back of the head.

However, the sergeant saw no physical evidence, such as torn

clothing or injury to Woods’s body, which led him to believe that

Battle had fought with or struck Woods that night.

The sergeant testified that he found Battle’s body on the living

3 room floor. A crime scene investigator with the Bibb County Sheriff’s

Office took photos of and collected evidence from Woods’s residence.

The photographs, which were published to the jury, showed Battle’s

body lying face-down on the living room floor in front of a chair.

Photographs also showed two holes in Battle’s back and blood

spatter on the carpet and ceiling. Photographs taken in the bedroom

showed a hunting rifle lying on the bed next to a spent shell casing.

The investigator testified that, as she took photographs of Battle’s

body, she saw no weapons lying close to his body.

The forensic pathologist who performed the autopsy of Battle’s

body testified that he determined from Battle’s wounds that the

bullets had traveled from back to front, indicating that Battle was

shot in the back. He saw no soot or stippling on the entry wounds,

which indicated the gun was likely fired from three or more feet from

Battle’s back. He concluded that Battle’s cause of death was “a

gunshot wound of the torso,” and the manner of death was homicide.

Finally, on the issue of Woods’s status as a convicted felon, the State

submitted a certified copy of Woods’s 1994 felony conviction for

4 aggravated assault with intent to rape.

2. Woods contends that his trial counsel’s “advice against

testifying” was constitutionally deficient, given the trial court’s

initial decision not to give counsel’s requested charge on voluntary

manslaughter. For the following reasons, we disagree.

To prevail on a claim of ineffective assistance of counsel, a

defendant generally must show that counsel’s performance was

constitutionally deficient and that the deficient performance

resulted in prejudice to the defendant. See Strickland v.

Washington, 466 U.S. 668, 687–695 (1984); Wesley v. State, 286 Ga.

355, 356 (2010). To satisfy the deficiency prong, a defendant must

demonstrate that his attorney “performed at trial in an objectively

unreasonable way considering all the circumstances and in the light

of prevailing professional norms.” Romer v. State, 293 Ga. 339, 344

(2013) (citation omitted). See also Strickland, 466 U. S. at 687–688.

This requires a defendant to overcome the strong presumption that

trial counsel’s performance “fell within a wide range of reasonable

professional conduct.” See Marshall v. State, 297 Ga. 445, 448

5 (citation and punctuation omitted). “If an appellant fails to meet his

or her burden of proving either prong of the Strickland test, the

reviewing court does not have to examine the other prong.”

Lawrence v. State, 286 Ga. 533, 533–534 (2010).

Counsel’s theory of defense was that Woods was provoked by

Battle. Prior to trial, defense counsel filed requests to charge that

included a charge on voluntary manslaughter. At the end of the first

day of testimony, during a discussion of the requests to charge, the

State objected to the voluntary manslaughter charge. Defense

counsel responded, arguing:

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Wesley v. State
689 S.E.2d 280 (Supreme Court of Georgia, 2010)
Lawrence v. State
690 S.E.2d 801 (Supreme Court of Georgia, 2010)
Marshall v. State
774 S.E.2d 675 (Supreme Court of Georgia, 2015)
Romer v. State
745 S.E.2d 637 (Supreme Court of Georgia, 2013)
Washington v. State
755 S.E.2d 160 (Supreme Court of Georgia, 2014)
Dixon v. State
808 S.E.2d 696 (Supreme Court of Georgia, 2017)
Newman v. State
844 S.E.2d 775 (Supreme Court of Georgia, 2020)

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Woods v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/woods-v-state-ga-2025.