Supreme Court of Georgia

Smith v. State

April 30, 2024318 Ga. 868

Summary

The court affirmed Smith’s convictions and sentence. It held that the medical-diagnosis hearsay exception does not permit a defendant to testify to a medical diagnosis itself, although Smith could describe his PTSD symptoms. Even assuming the trial court abused its discretion by allowing impeachment questioning about Smith’s prior military charge, the error was harmless because the evidence strongly supported the State’s account and the charge was unlikely to affect the verdict.