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assistance of trial counsel can be based on bond conditions imposed on a defendant during appeal of a criminal conviction . … Nor has appellant shown prejudice—that is, a reasonable likelihood that without Aronow's consent the bond conditions would have been less onerous.” 15. CHARACTER EVIDENCE, FAILURE TO OBJECT Ballard v. State, 297 Ga. 248, 773 S.E.2d 254 (June 1, 2015). Felony murder and related convictions affirmed; 1. no ineffective assistance where counsel failed to stipulate to defendant’s prior convicted felon status, allowing/requiring State to prove his prior offenses . “[W]hile it is true that a trial court may abuse its discretion when it fails to allow a defendant to stipulate to his or her convicted felon status, such abuse of discretion only occurs where ‘(1) a defendant's prior conviction is of the nature likely to inflame the passions of the jury and raise the risk of a conviction based on improper considerations, and (2) the purpose of the evidence is solely to prove the defendant's status as a convicted felon.’ Ross v. State, 279 Ga. 365, 368(2) (614 S.E.2d 31) (2005). Here, Ballard's prior convictions for aggravated assault and burglary with the intent to commit aggravated assault were ‘not of the nature likely to inflame the passions of the jury.’ See Hill v. State, 290 Ga. 493, 498(6) (722 S.E.2d 708) (2012) (a prior aggravated assault conviction used to establish a defendant's status as a convicted felon is ‘not of the nature likely to inflame the passions of the jury,’ even where the crimes for which the defendant was being tried involved felony murder and aggravated assault).” 2. “Trial counsel's failure to redact the indictment to eliminate references to Ballard's prior convictions also could not amount to ineffective assistance, as ‘[p]roof of [Ballard's] previous conviction was a necessary element of the state's proof’ that Ballard was a convicted felon in possession of a firearm. See Prather v. State, 247 Ga. 789, 790(2) (279 S.E.2d 697) (1981).” 3. “Similarly, the fact that trial counsel did not redact an order that referenced Ballard's first offender status being revoked did not amount to ineffective assistance. Here, in order for the State to show that Ballard was a convicted felon, the State needed to present evidence that Ballard's first offender status had been revoked with respect to the counts of the former indictment to which he had pled guilty. See Davis v. State, 269 Ga. 276, 277(2) (496 S.E.2d 699) (1998) (‘A first offender's guilty plea does not constitute a conviction’).” Hutchins v. State, 326 Ga.App. 250, 756 S.E.2d 347 (March 14, 2014). Conviction for child cruelty by permitting her child to be present where meth was being manufactured reversed; counsel was ineffective in failing to object to prejudicial bad character evidence. “The trial transcript reveals that the lead investigator testified at length during the State's case in chief concerning Hutchins' alleged involvement in a suspected illegal ‘pill ring.’ Counsel interposed no objection to this testimony, and the record does not indicate that the State had been allowed to inquire into Hutchins' participation in the pill ring as a similar transaction.” Investigator also stated his opinion that defendant “was being deceptive” in denying knowledge of her mother’s meth manufacturing operation. “The prosecutor also thoroughly cross-examined Hutchins on her involvement in what the State characterized as a ‘massive narcotics pill ring.’ During cross-examination, the prosecutor stated that the confidential informant had implicated Hutchins in the pill ring, asserted that Hutchins had bought pills at the behest of a specific person, and argued that Hutchins knew that some of these pills were being distributed to her mother.” “At the hearing on Hutchins' motion for new trial, Hutchins' trial counsel offered no strategic basis for admitting the evidence; rather she testified that she did not think the evidence was harmful. As there was no strategic reason for failing to object to this bad character evidence, counsel's performance was deficient and the trial court erred in holding otherwise. See Emilio v. State, 263 Ga.App. 604, 605(1), 588 S.E.2d 797 (2003) (Counsel was deficient in eliciting statements accusing the defendant of trafficking, statements which constituted bad character evidence.); Harris v. State, 251 Ga.App. 879, 881(3), 555 S.E.2d 485 (2001) (Counsel was deficient in failing to object to testimony that defendant had been charged with robbery in another jurisdiction.).” “It is clear that the prosecution used the evidence concerning Hutchins' involvement in the alleged pill ring to cast her in the role of a drug dealer with an intimate knowledge of the drug trade gleaned from personal experience. Such evidence also demonstrates, as the prosecutor argued, that Hutchins had a propensity to commit the type of crime for which she was charged—buying pills for someone else. Thus, the evidence severely undermined Hutchins' credibility with respect to key issues at trial: whether she knew that the pseudoephedrine pills and other chemicals in the house were being used by her mother to manufacture methamphetamine and, given that knowledge, whether she intentionally permitted her child to be present where methamphetamine was being manufactured. Given that the evidence in this case was circumstantial and that the jury's finding of guilt turned on what Hutchins reasonably should have deduced from the evidence recovered from the home, we must conclude that there is a reasonable probability that the outcome would have been different had it not been for trial counsel's deficient performance in failing to exclude this bad character evidence.” Vanstavern v. State, 293 Ga. 123, 744 S.E.2d 42 (June 3, 2013). Murder and related convictions affirmed; no ineffective assistance where defense counsel chose not to object to trial court’s erroneous disclosure to jury of redacted count of indictment. “At the hearing on the motion for new trial, as amended, trial counsel testified that he did not move for a

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