Supreme Court of Georgia
Ryals v. State
March 4, 2025321 Ga. 151
Summary
The court affirmed Ryals's convictions, holding that none of his four ineffective-assistance claims established deficient performance and prejudice. Counsel reasonably chose not to subpoena a cooperative witness, the unproduced text messages would have been cumulative and their absence was not prejudicial, the proposed criminal-history evidence was either inadmissible, cumulative, or speculative, and the decision to pursue an all-or-nothing self-defense strategy without a voluntary-manslaughter charge was reasonable. The court also rejected Ryals's cumulative-prejudice claim.