Supreme Court of Georgia

State v. Spratlin.

March 11, 2019826 S.E.2d 36

Summary

The Supreme Court of Georgia reversed the order granting Spratlin a new trial. Although counsel performed deficiently by failing to object to the prosecutor's improper closing argument concerning Spratlin's post-arrest silence, the deficiency did not create a reasonable probability of a different verdict because the comments were limited, the jury received a strong curative instruction, and the evidence of guilt was substantial.