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361(27) (496 S.E.2d 674) (1998) (holding that Georgia courts should take a permissive approach to admitting mitigating evidence that is relevant to the defendant's character, background, or blameworthiness but noting that ‘[t]he victim's bad character is not admissible in the sentencing phase’ ).” Williams v. State, 279 Ga. 731, 620 S.E.2d 816 (October 11, 2005). Defendant, a police officer, was convicted of murdering his former girlfriend and her family and sentenced to life without parole. “We agree with [defendant] that the trial court erred when it refused, during the penalty phase, to allow him to try on a police uniform discovered in [victim’s] home. See Barnes v. State, 269 Ga. 345 (496 S.E.2d 674) (1998); Blankenship v. State, 251 Ga. 621, 624 (308 S.E.2d 369) (1983) (evidence of defendant’s guilt or innocence cannot be excluded in penalty phase, even though guilty verdict was rendered in guilt/innocence phase). We conclude, however, that due to the limited nature and relevance of this mitigating evidence, the overwhelming evidence of [defendant]’s guilt and the fact that the jury rejected the death sentence and sentenced [defendant] to life without parole, that the error was harmless.” Lewis v. State, 279 Ga. 756, 620 S.E.2d 778 (September 19, 2005). Defendant’s death sentence upheld. “It is well-settled that in a sentencing trial the State may present evidence of a defendant’s bad character, including previous convictions and non-adjudicated offenses. [Cits.]” Pace v. State, 271 Ga. 829, 524 S.E.2d 490 (December 3, 1999). Defendant’s convictions for capital murder, rape, and related offenses affirmed; King v. State, 273 Ga. 258, 539 S.E.2d 783 (November 30, 2000). “The trial court did not err by denying King’s pre-trial motions seeking authorization to present evidence about the alleged lack of deterrent effect of the death penalty, about the effects of electrocution, about alleged lingering doubt surrounding other persons’ convictions, and about life imprisonment in general. Barnes v. State, 269 Ga. 345, 359-360(27), 496 S.E.2d 674 (1998). The trial court did authorize King to introduce evidence relevant to his own ‘background and character’ as this Court has required. Id. at 360, 496 S.E.2d 674.” Nance v. State, 272 Ga. 217, 526 S.E.2d 560 (February 28, 2000). Murder conviction affirmed, but death penalty reversed (based on error in failing to strike juror for cause). Trial court erred in allowing State to present statements made by defendant to State’s mental health evaluator in its guilt/innocence case in chief, rather than in rebuttal to defendant’s sentencing phase expert testimony (or defendant’s own testimony). Pretrial, defendant had announced his intention to present expert mental health testimony at the sentencing phase, and trial court thus required him to submit to State mental health exam by State psychologist. The State psychologist had defendant execute a Miranda waiver before interviewing him. “While the State was presenting its case-in-chief in the guilt-innocence phase, it called Dr. Sapp as a witness. Over Nance's objection, she testified that Nance told her he had ingested cocaine, Dom Perignon, and marijuana on the morning of the murder. Dr. Sapp was not qualified as an expert at that time, was not referred to as a doctor, and she presented no mental health testimony. Nance argues that Dr. Sapp's testimony could only have been presented in rebuttal to the testimony of Nance's mental health expert in the sentencing phase. The State argues that Dr. Sapp did not testify as a mental health expert in the guilt-innocence phase and that Nance's statement to her was admissible because it was voluntary and preceded by Miranda warnings.” “[T]he purpose of the rule requiring the defendant to submit to a State mental health examination under these circumstances is to permit the State to formulate a response or a rebuttal to the testimony of the defendant's mental health expert. See [ Estelle v. Smith, 451 U.S. 454, 465, 101 S.Ct. 1866, 68 L.Ed.2d 359 (1981)]; Lynd [ v. State, 262 Ga. 58, 414 S.E.2d 5 (1992)]; Motes v. State, 256 Ga. 831(2), 353 S.E.2d 348 (1987). This purpose was subverted in Nance's case when, during the State's case-in-chief in the guilt-innocence phase, the State's expert stripped off her medical title and testified as a lay witness about what the defendant told her during the examination. Access to the defendant's psyche was permitted so the State could respond to the defendant's mental health expert, not to gather incriminating statements that bolster the State's case. A defense lawyer in a capital case, who must prepare for the sentencing phase should his client be convicted, should not be forced to choose between presenting mental health mitigation evidence through an expert and providing the State with evidence with which to convict his client. … We therefore restate our holding in Abernathy [ v. State, 265 Ga. 754, 462 S.E.2d 615 (1995)] that when a defendant must submit to a court-ordered mental health examination because he wishes to present expert mental health testimony at his trial, the State expert may only testify in rebuttal to the testimony of the defense expert or to rebut the testimony of the defendant himself. [fn: This rule applies whether the defendant wishes to present expert mental health testimony in the guilt-innocence phase to support an insanity defense, see Motes, 256 Ga. at 832(2), 353 S.E.2d 348, or as mitigation evidence in the sentencing phase. See Abernathy, 265 Ga. at 754–55, 462 S.E.2d 615. To the extent Hittson v. State, 264 Ga. 682(2), 449 S.E.2d 586 (1994) authorized a State expert to testify in response to lay witness