Supreme Court of Georgia

Smith v. State

April 30, 2024318 Ga. 868

Summary

The Supreme Court of Georgia affirmed Smith's felony‑murder convictions, holding that the trial court correctly excluded his lay testimony about a PTSD diagnosis because Rule 803(4) does not cover medical diagnoses, and that any error in admitting impeachment evidence of a prior military charge was harmless. The Court applied an abuse‑of‑discretion standard to the evidentiary rulings and a harmless‑error analysis to the impeachment issue.