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B. ATTORNEY GENERAL Georgia Public Defender Standards Council v. Buchanan, 285 Ga. 553, 679 S.E.2d 712 (June 15, 2009). No conflict of interest prevented Attorney General from representing the Public Defender Standards Council in a fee dispute with private appointed counsel after the underlying criminal prosecution was concluded. “Because [defendant] Buchanan's criminal case is completed and because the Attorney General's representation of the Council does not involve the merits of Buchanan's criminal case but only whether the Council should pay attorney fees for the efforts of Buchanan's counsel to be reinstated as counsel after substitute counsel was appointed for Buchanan by the Standards Council, we conclude there is no conflict in the present case that merits the Attorney General's disqualification.” C. BOLSTERING WITNESS CREDIBILITY Ford v. State, 298 Ga. 560, 783 S.E.2d 906 (March 7, 2016). Malice murder and related convictions affirmed; no mistrial required where prosecutor called defense witness a liar in closing argument. “[A]lthough the prosecutor should have avoided personalizing the argument, his comments in closing as to his reasons for not calling Hickey to testify during the State’s case in chief or as to the reliability of Hickey’s testimony, which were in response to defense counsel’s argument, were supported by the evidence.” Bell v. State, 294 Ga. 443, 754 S.E.2d 327 (January 27, 2014). Malice murder and related convictions affirmed; prosecutor’s question to witness improperly vouched for witness’s credibility, but no prejudice from counsel’s failure to object. In opening statement, defense counsel said the evidence would show that witness Smith and others were lying. “During the prosecutor's direct examination of Smith, the prosecutor asked: ‘Has anybody ever accused you—have I ever accused you, or anybody else accused you of lying or giving a second statement or changing your story in any way?’ Smith answered, ‘No.’” “The prosecutor's question elicited that neither he nor others, like the police officers who obtained the witness' statement, had ever accused the witness of lying. Accordingly, we do not agree with the trial court's conclusion that this question did not serve to improperly vouch for the witness' credibility.” No prejudice, however, “[g]iven the substantial evidence of Bell's guilt.” Thompson v. State, 321 Ga.App. 756, 743 S.E.2d 446 (May 14, 2013). Aggravated child molesting and related convictions affirmed; no improper bolstering in prosecutor’s closing argument. “As the State noted, the psychologist had testified about certain reactions that were common in sexually abused children, including the reluctance to verbalize about the sexual abuse, that it was common for victims to tell a friend, and also common for them to not make an outcry at the time of the abuse. The State's references in closing argument were to the psychologist's forensic findings and the inferences thereto, not to any opinion as to the veracity of the victim. Thompson had argued in his closing argument that the victim's reactions-including that she had not made an outcry for two years did not ‘make sense.’” Fuller v. State, 320 Ga.App. 620, 740 S.E.2d 346 (March 21, 2013). Armed robbery and related convictions affirmed; no improper comment “on the veracity of the officer witnesses by stating that the Clayton County Police were overloaded with work. … Here, the State's closing comments that the officers would not falsely accuse someone were merely comments urging the jury to make a deduction about the officers' veracity from the facts, and such comments do not constitute an opinion about the officers' veracity.” Citing Manley (January 26, 2009), below. Humphrey v. Lewis, 291 Ga. 202, 728 S.E.2d 603 (June 18, 2012). Habeas court erred in granting relief as to defendant’s malice murder conviction; prosecutor’s comments in closing argument that witness was “obviously compelling” and “obviously truthful” weren’t improper. “[A] review of the allegedly-improper remarks in context shows that, prior to the State's argument, the defense urged the jury numerous times in closing argument to find Kellee's testimony unreliable. … The State was entitled to respond to defense counsel's remarks. See Morgan v. State, 267 Ga. 203, 204(1) (476 S.E.2d 747) (1996). In doing so, the prosecutor told jurors the trial court would instruct them regarding how to assess the reliability of eyewitness identification, and he informed jurors of several factors that the trial court would charge them were permissible to consider in assessing the reliability of eyewitness identifications, such as the witness' opportunity to view the alleged perpetrator. [Cit.] Then the prosecutor indicated that going through the process of applying those factors to the evidence would ‘reinforce how compelling Kelly [sic] Dunn's testimony was.’” Manley v. State, 284 Ga. 840, 672 S.E.2d 654 (January 26, 2009). No improper argument where prosecutor, responding to claims that police had framed defendant, argued that “the investigators, officers, and the prosecuting attorney involved in the murder investigation would not sacrifice their careers in law enforcement to frame Manley.” “In rebutting Manley's contentions, ‘the State's comments did not constitute an opinion about [the] veracity [of these witnesses]. The comments
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