Gates v. the State

Summary

The court affirmed Gates’s convictions, holding that the challenged text message was admitted for its effect on Gates and therefore was not hearsay. It further held that any unpreserved error concerning firearms evidence did not satisfy the plain-error standard, and that Gates waived appellate review of unobjected-to prosecutorial comments during closing argument. Gates also failed to establish ineffective assistance because counsel’s firearm-evidence decisions were reasonable strategy and the alleged deficiencies did not create a reasonable probability of a different result.