Supreme Court of Georgia

Henderson v. State

October 19, 2020310 Ga. 231

Summary

The court affirmed Henderson’s convictions and life sentence, holding that the three-and-a-half-year delay did not violate his constitutional speedy-trial rights because the trial court properly balanced the relevant factors and found no sufficient prejudice. It also held that Henderson failed to establish ineffective assistance because he could not show outcome-related prejudice from the untimely speedy-trial demand, deficient investigation, or counsel’s impeachment strategy. The court additionally held that an earlier rule treating an untimely statutory speedy-trial demand as automatically prejudicial was unsound and limited that rule accordingly.