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part. I think it ... made the State look[ ] pretty incompetent that the [Chief ADA was] the only one that they could bring in to testify at the last minute ...’ as to the victim's emotional state after presenting numerous other witnesses. And the record demonstrates that the attorney successfully objected when the testimony went beyond the scope of his agreement on this point. Accordingly, Keaton's counsel's acquiescence in the prosecutor's limited testimony on this point was a matter of trial strategy, and it is well settled that ‘matters of reasonable tactics and strategy, whether wise or unwise, do not amount to ineffective assistance of counsel.’ (Citations and punctuation omitted.) Dyer v. State, 295 Ga.App. 495, 498(1) (672 S.E.2d 462) (2009).” Wilcox v. State, 309 Ga.App. 538, 711 S.E.2d 67 (May 6, 2011). Rape and related convictions affirmed; no ineffective assistance where counsel “in stipulating that the blood found on a pair of jeans in Wilcox's home was that of the victim. … At trial, counsel argued to the jury that the jeans had been contaminated by the victim's blood when an officer brought them from Wilcox's house to the crime scene. He established that an officer moved the jeans, and that there was a considerable amount of blood in the victim's home. He elicited admissions from the crime scene investigator that the officer's conduct in moving the jeans into a crime scene was improper and had the potential to contaminate the evidence. Stipulating to the identity of the blood on the jeans was entirely consistent with counsel's argument that the blood was contamination caused by the police officer's conduct rather than blood transferred to Wilcox's pants at the time of the crime.” Davenport v. State, 308 Ga.App. 140, 706 S.E.2d 757 (March 2, 2011). Defendants’ convictions for methamphetamine possession and related offenses affirmed; no ineffective assistance where counsel elected not object to officer’s qualifications as an expert on clandestine meth labs “for fear that [the prosecutor] would get up and further bolster this witness and make it even worse.” Gibson v. State, 308 Ga.App. 63, 706 S.E.2d 585 (February 23, 2011). Drug trafficking and related convictions affirmed; though counsel’s performance was deficient for failing to object to questions about possible sentence defendant faced, no harm shown. “The ground for mistrial overlooked by Gibson's counsel was a violation of the general procedural rule prohibiting cross-examination into potential sentences because a jury should consider only guilt and innocence. Perkins, supra, 288 Ga.App. at 802; State v. Vogleson, 275 Ga. 637, 640-641(2) (571 S.E.2d 752) (2002). Because there was no evidence of any deal between Gibson and the State, the questions seeking information about Gibson's potential sentences did not fall within the exception to the general rule created by the Supreme Court in Vogleson. 275 Ga. at 640(1). The trial court's curative instruction went only to the last question posed and was given only because Cohen's counsel overstated the minimum sentence, not because the entire line of questioning was prohibited. It therefore appears Gibson's trial counsel overlooked a ground for possible mistrial and an opportunity for a more detailed curative instruction.” Any harm to defendant, however, was merely “speculative.” Questions whether the rationale for this rule is still valid: “We note that the prohibition against the jury learning about sentences during the guilt and innocence phase appears to have originated with a 1970 statute that was repealed in 1974. See Cloud v. State, 136 Ga.App. 244 (220 S.E.2d 763) (1975): ‘the reasoning of the court in Moore v. State, [228] Ga. 662, [665] (187 S.E.2d 277), ... to the effect: “To allow the jury to consider the various sentences for the various offenses authorized by the court's instruction before a determination of guilt would be to repeal the intent of the legislation providing for a prior determination of guilt before considering punishment in felony cases,” would appear no longer to be applicable.’ Id. at 246(1).” Flint v. State, 308 Ga.App. 532, 707 S.E.2d 498 (February 22, 2011). Defendants’ armed robbery convictions affirmed; no ineffective assistance for failure to object to references to other robberies at same store. Defense counsel testified on motion for new trial “that, in his opinion, the evidence was not relevant to his client because the witnesses testified that they recognized Sanchez at the show-up because he was previously employed at the store. As counsel testified, ‘[o]bviously, if they had seen him at any of the other robberies, they would have identified him at that time.’” This strategic decision didn’t amount to ineffective assistance. Robinson v. State, 308 Ga.App. 45, 706 S.E.2d 577 (February 22, 2011). Child molestation conviction affirmed; no ineffective assistance for failure to demand pre-trial hearing on admissibility of child hearsay. “As this Court has held, ‘OCGA § 24-3-16 does not require a hearing to determine indicia of reliability be held prior to receiving the testimony.’ (Emphasis added.) Xulu v. State, 256 Ga.App. 272, 275(4) (568 S.E.2d 74) (2002). ‘Moreover, there is no requirement that the trial court make a specific finding of sufficient indicia of reliability in order for the out-of-court statements of child victims to be admissible.’ Id . It should be obvious that trial counsel was under no obligation to invoke his client's legal right to a hearing designed to protect that client's interests if the invocation of that abstract right would, in his professional judgment of the circumstances presented by a specific case, do actual harm to those
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