☢ test - Í

763 (June 17, 2013); Davis v. State , 329 Ga.App. 797, 764 S.E.2d 588 (October 29, 2014). Schofield v. Holsey, 281 Ga. 809, 642 S.E.2d 56 (February 26, 2007). Footnote 1: “The Supreme Court of the United States has held that it is the prejudice arising from ‘counsel’s errors’ that is constitutionally relevant, not that each individual error by counsel should be considered in a vacuum. Strickland [ v. Washington, 466 U.S. 668, 687(III) (104 S.Ct. 2052, 80 L.Ed.2d 674) (1984)]. Accordingly, the cases in which the Court of Appeals has held that the cumulative effect of counsel’s errors should not be considered are disapproved. See Anderson v. State, 282 Ga.App. 58, 62(3) (637 S.E.2d 790) (2006); Fields v. State, 281 Ga.App. 733, 737(2) (637 S.E.2d 136) (2006); Hutchens v. State, 281 Ga.App. 610, 613(2) (636 S.E.2d 773) (2006); Tyler v. State, 279 Ga.App. 809, 812(3) (632 S.E.2d 716) (2006); Frazier v. State, 278 Ga.App. 685, 690(3) (629 S.E.2d 568) (2006); Davenport v. State, 278 Ga.App. 16, 19(2) (628 S.E.2d 120) (2006); Zepp v. State, 276 Ga.App. 466, 475(5) (623 S.E.2d 569) (2005); Fitz v. State, 275 Ga.App. 817, 824- 825(4) (622 S.E.2d 46) (2005); Cornelius v. State, 273 Ga.App. 806, 808(2) (616 S.E.2d 148) (2005); Brooks v. State, 273 Ga.App. 691, 695(4) (615 S.E.2d 829) (2005); Howren v. State, 271 Ga.App. 55, 58(5) (608 S.E.2d 653) (2004); Hodges v. State, 260 Ga.App. 483, 486-487(5) (580 S.E.2d 614) (2003); Baker v. State, 259 Ga.App. 433, 435(3) (577 S.E.2d 282) (2003); Whited v. State, 258 Ga.App. 195, 200(8) (573 S.E.2d 449) (2002); Holland v. State, 250 Ga.App. 24, 28(4) (550 S.E.2d 433) (2001); Osborne v. State, 239 Ga.App. 308, 309(1) (521 S.E.2d 226) (1999); Johnson v. State, 236 Ga.App. 61, 66(3)(e) (510 S.E.2d 918) (1999); Carl v. State, 234 Ga.App. 61, 65(2)(g) (506 S.E.2d 207) (1998). Although the combined effects of trial counsel’s errors should be considered together as one issue, it remains the case that ‘[t]his State does not recognize the cumulative error rule.’ Bridges v. State, 268 Ga. 700, 708(9) (492 S.E.2d 877) (1997).” Elaborated on in Waits (April 24, 2007), above. Accord, Venegas v. State , 285 Ga.App. 768, 647 S.E.2d 422 (June 8, 2007); Phillips v. State , 285 Ga. 213, 675 S.E.2d 1 (February 9, 2009); Sears v. Humphrey , 294 Ga. 117, 751 S.E.2d 365 (November 18, 2013). Distinguished, Gilford v. State , 295 Ga.App. 651, 673 S.E.2d 40 (January 23, 2009) ( Schofield only applies in context of ineffective assistance claims); Gear v. State , 288 Ga. 500, 705 S.E.2d 632 (February 7, 2011) (cumulative effect only considered regarding attorney error, not court error); Reese v. State , 289 Ga. 446, 711 S.E.2d 717 (June 27, 2011) (same as Gear ); Humphrey v. Lewis , 291 Ga. 202, 728 S.E.2d 603 (June 18, 2012); Chatman v. Walker , 297 Ga. 191, 773 S.E.2d 192 (June 1, 2015); Blackmon v. State , A15A1834, ___ Ga.App. ___, 785 S.E.2d 59, 2016 WL 1138776 (March 24, 2016) (Physical precedent only). Burk v. State , 253 Ga.App. 272, 558 S.E.2d 726 (December 11, 2001). “[E]ach claim of inadequate representation must be examined independently of other claims, as Georgia does not recognize the cumulative error rule .” Accord numerous cases including Johnson v. State , 236 Ga.App. 61, 510 S.E.2d 918 (January 21, 1999); Zepp v. State , 276 Ga.App. 466, 623 S.E.2d 569 (November 18, 2005); Frazier v. State , 278 Ga.App. 685, 629 S.E.2d 568 (April 7, 2006); Tyler v. State , 279 Ga.App. 809, 632 S.E.2d 716 (June 15, 2006); Callahan v. State , 280 Ga.App. 323, 634 S.E.2d 102 (July 7, 2006); Hutchens v. State , 281 Ga.App. 610, 636 S.E.2d 773 (September 20, 2006); Fields v. State , 281 Ga.App. 733, 637 S.E.2d 136 (October 4, 2006). Overruled, see Schofield (February 26, 2007), above. 32. DAMAGING EVIDENCE, PRESENTING See also subheading CHARACTER EVIDENCE, OPENING DOOR, above Jackson v. State, A15A2137, 336 Ga.App. 70, ___ S.E.2d ___, 2016 WL 822115 (March 3, 2016). Armed robbery and related convictions affirmed. Counsel wasn’t deficient for eliciting testimony about defendant’s invocation of the right to counsel, and referring to it in closing argument. “At the hearing on Jackson’s motion for new trial, counsel testified that the purpose of his cross-examination question to the law enforcement officer was to emphasize that Jackson had turned himself in to the authorities, and he explained that he made the comments in closing argument to rehabilitate and enhance the credibility of Jackson’s father, who had testified as a defense witness and described Jackson’s movements and demeanor the night before and the morning after the crime. … In light of the evidence which counsel had to meet, we cannot say that counsel’s effort to [highlight Jackson’s act of turning himself in to authorities and to rehabilitate his father as a defense witness were] unreasonable.” State v. Reynolds, 332 Ga.App. 818, 775 S.E.2d 187 (July 8, 2015). Aggravated assault and related convictions reinstated; trial court erred by granting motion for new trial based on ineffective assistance of counsel. Counsel wasn’t deficient in presenting information about defendant’s history of drug trafficking charges, even where State couldn’t have elicited that testimony. “[C]ounsel’s reasonable strategy was to portray Reynolds as a drug dealer to support the defense's theory that his fingerprint was found on the stolen car because he sold drugs to someone driving the same car, not because he was involved in the armed robbery.” Citing Henderson v. State , 285 Ga. 240, 675 S.E.2d 28 (2009) (“trial counsel was not ineffective for eliciting testimony that portrayed his client as a drug dealer because it was a reasonable trial strategy to elicit such testimony to show that the defendant was present at the scene of an armed robbery to sell drugs,