Supreme Court of Georgia

Payne v. State

February 6, 2024318 Ga. 249

Summary

The court affirmed Payne’s convictions for felony murder and related offenses arising from the death of a one-year-old child. It held that the evidence was constitutionally and statutorily sufficient, the exclusion of the co-defendant’s drug-use evidence was not an abuse of discretion, and the requested grave-suspicion instruction was adequately covered by the charge as a whole. The court also rejected Payne’s ineffective-assistance claim because counsel’s decision not to seek severance was a reasonable trial strategy.