Supreme Court of Georgia

Flannigan v. the State.

February 4, 2019305 Ga. 57

Summary

The court affirmed Flannigan’s convictions, rejecting two ineffective-assistance claims and his challenge to evidence that he attacked a witness who was speaking with police. It held that Flannigan failed to show prejudice from counsel’s failure to challenge the fingerprint expert’s qualifications and failed to show deficient performance from counsel’s failure to question a co-indictee about possible sentences. The court also held that the witness-attack evidence was relevant as circumstantial evidence of consciousness of guilt and was not inadmissible merely because it incidentally implicated character.