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stipulated polygraph examination signed by counsel and the defendant would foreclose post-conviction recriminations about having submitted to a polygraph exam, there is no constitutional requirement that ramification explanation be so documented. Accordingly, [defendant’s] contention that the polygraph exam was procedurally flawed is without merit.” Accord, Hortman v. State , 293 Ga.App. 803, 670 S.E.2d 99 (October 3, 2008) (no ineffective assistance for failing to suggest that defendant take polygraph where there was no evidence that State would have stipulated to its admission). Johnson v. State, 272 Ga.App. 385, 612 S.E.2d 518 (March 14, 2005). Aggravated child molestation and related convictions affirmed. “Johnson … argues that the trial court erred in excluding evidence that [detective] offered Johnson a polygraph examination and that Johnson accepted the offer. We disagree. ‘In Georgia, the law of evidence in criminal trials is that the results of polygraph examinations are probative and admissible upon express stipulation, but that all other evidence concerning polygraphs is nonprobative, irrelevant and inadmissible.’ Brown v. State, 175 Ga.App. 246, 249(4) (333 S.E.2d 124) (1985). As Johnson only sought admission of his agreement to take a polygraph test, rather than any results, we find no error in the trial court’s ruling.” Height v. State, 278 Ga. 592, 604 S.E.2d 796 (November 8, 2004). In capital murder prosecution, trial court erred in denying defendant’s pretrial motion to admit polygraphy test results as mitigation evidence during penalty phase of case. “Georgia’s general ban on the admission of polygraph test results absent the parties’ stipulation should not be applied automatically in the sentencing phase of a capital case so as to prevent the defendant from presenting a favorable polygraph test result. ‘[E]videntiary rules may be trumped by a defendant’s need to introduce mitigation evidence. [Cits.]’ Barnes v. State, [269 Ga. 345, 358(27), 496 S.E.2d 674 (1998)]. Therefore, to the extent that Baxter v. Kemp, 260 Ga. 184, 187(8), 391 S.E.2d 754, fn. 4 (260 Ga. 184, 391 S.E.2d 754) (1990) or any other case intimates that unstipulated polygraph results are per se inadmissible as mitigation evidence, it is hereby overruled. We caution, however, that today’s holding should not be misconstrued as authorizing the admission of polygraph test results in the penalty phase of every capital case. While the scope of permissible mitigation evidence is wide, it is not so extensive as to allow ‘the wholesale admission of all evidence contended to be mitigating without respect to its reliability ...’ Gissendaner v. State, 272 Ga. 704, 714(12), 532 S.E.2d 677 (2000). When the defendant seeks to introduce unstipulated polygraph test results as mitigation evidence, the trial court must exercise its discretion to determine whether those results are sufficiently reliable to be admitted. [Cit.]” Distinguished in Waldrip v. Head , 279 Ga. 826, 620 S.E.2d 829 (October 12, 2005) (no attempt to show reliability of polygraph results). Franks v. State, 278 Ga. 246, 599 S.E.2d 134 (June 28, 2004). Malice murder and related convictions affirmed. “[B]rief, non-responsive reference to a polygraph test did not open the door to the cross-examination of Watts about her polygraph test. Additionally, the polygraph reference did not prejudice Franks because it indicated nothing about the results of the polygraph.” Farmer v. State, 268 Ga.App. 831, 603 S.E.2d 16 (June 25, 2004). Armed robbery and related convictions affirmed. Testimony that victim had agreed to take a polygraph test did not require reversal. “‘[N]ot every reference to a polygraph requires reversal.’ Allen v. State, 210 Ga.App. 447, 449 (436 S.E.2d 559) (1993). ‘The mere fact that the jury was apprised that a lie detector test was taken is not necessarily prejudicial if no inference as to the result is raised.’ (Footnote omitted.) Hayes v. State, 244 Ga.App. 12, 15(4) (534 S.E.2d 577) (2000). Here, no polygraph was even administered, and thus no inference as to the results of any polygraph test could have been raised. Accordingly, we find no error.” Sealey v. State, 277 Ga. 617, 593 S.E.2d 335 (March 1, 2004). Capital murder and related convictions affirmed. “The trial court did not err in excluding evidence regarding a polygraph examination administered to [witness]. The fact that [witness] entered into a stipulation with the State as to the admissibility of the results of her polygraph examination in any proceeding against her is irrelevant to the admissibility of those results in Sealey's trial, and Sealey had no similar stipulation with the State of his own regarding those results. [Cit.]” Collins v. State, 276 Ga. 726, 583 S.E.2d 26 (June 30, 2003). Malice murder conviction affirmed. “‘[T]he fact that a jury is apprised that a polygraph was taken does not necessarily result in prejudice if no inference is raised as to the result. [Cit.]’ Castleberry v. State, 274 Ga. 290, 293(3), 553 S.E.2d 606 (2001).” Note, however, “it has been held that it is error to allow evidence of a defendant's refusal to take a polygraph.” Thompson v. State, 262 Ga.App. 17, 585 S.E.2d 125 (June 26, 2003). Child cruelty and related convictions affirmed. “[W]here the defendant and the State do not stipulate that the results of a polygraph test taken by a witness would be admissible at trial, the questioning of a witness regarding those test results is impermissible. [Cit.] ‘Nonetheless, while in

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