Bates v. State

Summary

The Supreme Court of Georgia affirmed the denial of Larry Bates’s motion for a new trial after concluding that he failed to establish ineffective assistance of counsel. Counsel’s challenged decisions concerning PTSD evidence, the absence of a mental-illness notice, the subpoenaing of a VA physician, and the handling of expert testimony were either reasonable strategic decisions or did not cause prejudice. The court also held that any assumed deficiencies did not cumulatively create a reasonable probability of a different result.