Supreme Court of Georgia
Rhoden v. the State.
April 16, 2018813 S.E.2d 375
Summary
The court affirmed Rhoden’s convictions, concluding that the evidence was sufficient and that he failed to prove ineffective assistance of counsel. Counsel was not deficient for declining to seek a mistrial based on the prosecutor’s acceptance rather than exclusion of a juror, because Rhoden identified no authority extending Batson principles to that conduct. Counsel also was not ineffective for failing to seek severance because Rhoden did not establish that his co-defendant would actually testify at a separate trial.