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brother, trial counsel testified that he did not object because, after interviewing him, he believed he was a ‘loose cannon’ who became less credible the more he was ‘allowed to ramble.’ Trial counsel also testified that the statements made to the victim's brother concerning the argument between appellant and the victim were not worrisome because they were simply consistent with the testimony of the eyewitnesses. Trial counsel added that it was his practice to avoid alienating the jury by objecting unnecessarily to non-detrimental evidence and making it appear that he was trying to keep information from them. Compare Laye (November 15, 2011), below. Accord, Holmes v. State , 293 Ga. 229, 744 S.E.2d 701 (June 17, 2013) (counsel not ineffective in choosing not to object to hearsay he thought supported his theory that the murder weapon was co-defendant’s, not Holmes’s.). Rawls v. State, 315 Ga.App. 891, 730 S.E.2d 1 (May 17, 2012). Child molestation and related convictions affirmed. 1. No ineffective assistance where counsel failed to object to State’s opening statement “that commented on what evidence the defense would produce. [fn] But at the hearing on Rawls's motion for new trial, trial counsel testified that during the opening statement, he would not want to ‘appear as though we're trying to hide something, especially when [the defense would bring out the evidence mentioned by the State]. To stand up and try to block that doesn't seem to be a great tactical value.’ This is consistent with trial counsel's stated philosophy that ‘overall, I'm not one to necessarily just stand up for the purposes of correcting a record or — for instance, if something is potentially damaging or damaging to my client, if I'm going to draw a great deal more attention to it, that's a factor I will take into consideration.’ In light of this reasonable trial strategy, Rawls cannot demonstrate deficient performance on this basis.” Accord, Sowell v. State , 327 Ga.App. 532, 759 S.E.2d 602 (June 11, 2014) (counsel didn’t object to State’s evidence “because he did not want the jury to think the defense had anything to hide”). 2. No ineffective assistance where counsel failed to object to State’s closing argument, expressing prosecutor’s personal opinion. “At closing, the State's counsel attacked the defense theory that, based on Rawls's concern for a sexually charged note found in D.R.'s backpack, Rawls was an over-protective father. The State's counsel argued that this view was ‘a bunch of crap ... I call it like it is ... I don't want [a father] who tries to have sex with me when I'm ten years old.’ … With the benefit of hindsight, one can always argue that trial counsel's failure to object was something that no reasonable trial lawyer would do. Our task, however, is to determine whether, in the throes of closing argument, no reasonable attorney, listening to the inflection of the speaker's voice and judging the jurors' reactions, would choose to remain silent instead of objecting and calling attention to the improper argument. Here, [Rawls's] attorney reasonably chose silence, and we will not use hindsight to second-guess that decision on appeal. See Braithwaite v. State, 275 Ga. 884, 886(2)(b) (572 S.E.2d 612) (2002) (no ineffective assistance because attorney made reasonable strategic decision not to object to the State's improper ‘golden rule’ argument).” Accord, Lopez- Jiminez v. State , 317 Ga.App. 868, 733 S.E.2d 42 (October 9, 2012) (counsel could reasonably choose to respond by argument rather than objecting to prosecutor’s argument misstating facts); Williams v. State , 292 Ga. 844, 742 S.E.2d 445 (April 29, 2013) (same as Lopez-Jiminez ); Dorsey v. State , 331 Ga.App. 486, 771 S.E.2d 167 (March 24, 2015) (counsel could reasonably interpret prosecutor’s closing argument as permissible comment on defendant’s custodial statement, not impermissible comment on his failure to testify). Laye v. State, 312 Ga.App. 862, 720 S.E.2d 233 (November 15, 2011). Armed robbery conviction affirmed; counsel was deficient, but no prejudice, for failing to object to hearsay. Recording of defendant’s custodial statement included defendant’s mother asking him questions and repeating hearsay including “that one accomplice ‘told everybody you had a gun,’ and that someone said that Laye ‘had a shoot-out with the white guy.’” No prejudice in light of acquittals on firearms charges, and considering “Laye's own testimony … that he was a party to armed robbery even if he did not have a gun.” Compare Green (September 10, 2012), above. Ardis v. State, 290 Ga. 58, 718 S.E.2d 526 (November 7, 2011). Felony murder and related convictions affirmed; trial counsel’s representation was deficient for failing to object to admission of now-deceased victim’s statement to police. Victim “Langston died of unrelated causes prior to Ardis' trial. … Since Langston was interviewed by the police for the purpose of investigating and prosecuting the crimes that took place in the parking lot, his statement was clearly testimonial in nature. And because Langston was an unavailable witness and Ardis presumably had no prior opportunity to cross-examine him, admission of his statement into evidence violated the rule in Crawford. As such, trial counsel's failure to attempt to prevent the offending evidence from infecting the trial was deficient under the first prong of Strickland. ” No prejudice, however, in light of overwhelming evidence of guilt, including defendant’s own admission. Keaton v. State, 311 Ga.App. 14, 714 S.E.2d 693 (July 14, 2011). Convictions for rape and related offenses affirmed; no ineffective assistance based on failure to object to testimony by Chief ADA, regarding victim’s demeanor in prior interactions. “Keaton's lead trial attorney testified at the hearing on his motion for new trial that he did not object to the Chief ADA's taking the stand to say the victim had previously cried because he ‘didn't think it was very effective on his

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