Robinson v. the State

Summary

The Supreme Court of Georgia affirmed the trial court's denial of a new trial to Rico Robinson following an evidentiary hearing on his claim that trial counsel rendered ineffective assistance during his malice-murder trial. The Court held that counsel's failure to object to the exclusion of evidence of the victim's prior violence toward Robinson could not be ineffective assistance, because Robinson never made the prima facie showing of justification that would have made that evidence relevant to his sole defense of self-defense. It further held that counsel's inability to obtain a forensic-pathology expert could not have changed the outcome, given compelling evidence - more bullet wounds in the victim's back than chest and eyewitness testimony of repeated shots into his back - that Robinson did not act in self-defense. Finally, it held the trial court acted within its discretion in denying post-conviction funds for an expert, because no special need for the expert could be demonstrated.