Bates v. State

Summary

The Supreme Court of Georgia affirmed the denial of Larry Bates’s motion for a new trial, concluding that he failed to establish ineffective assistance of counsel in any of four asserted respects. Counsel’s decisions concerning PTSD-related defenses, the absence of a mental-illness notice, the subpoenaing of a treating psychologist, and the handling of the State’s expert were either reasonable strategic choices or did not cause prejudice. The court also concluded that any assumed prejudice from the subpoena and expert-testimony issues was insufficient cumulatively to undermine confidence in the verdict.