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witness' motivation in testifying is a proper and important function of the constitutionally protected right of cross- examination’). ‘It is especially important in a case where a witness or an accomplice may have substantial reason to cooperate with the government that a defendant be permitted to search for an agreement between the government and the witness. Whether or not such a deal existed is not crucial. What counts is whether the witness may be shading his testimony in an effort to please the prosecution. A desire to cooperate may be formed beneath the conscious level, in a manner not apparent even to the witness, but such a subtle desire to assist the state nevertheless may cloud perception.’ (Citations and punctuation omitted.) Hines v. State, 249 Ga. 257, 260(2), 290 S.E.2d 911 (1982).” Johnson v. State , 244 Ga.App. 128, 534 S.E.2d 480 (May 3, 2000). Armed robbery and related convictions affirmed; trial court properly restricted evidence regarding participation by State’s witness in drug sales at county jail. At trial, defense was allowed to cross-examine the witness on the subject; witness admitted participation in the drug sales, but denied that he had any deal with the State for his testimony in Johnson’s case, related to the drug sales or anything else. “Here, it is uncontroverted that [witness] has not been arrested for and has no pending charges related to drug sales at the jail. Absent pending charges, the jail scheme provides no basis by which ‘the partiality of [Lancaster] may be exposed by proof that he hopes to benefit in related cases from his cooperation with the prosecution in this case.’ Kinsman v. State, 259 Ga. 89, 91, 376 S.E.2d 845 (1989). To allow defense counsel to cross-examine Lancaster on specific instances of bad conduct at the jail is a prohibited form of impeachment. OCGA § 24-9-84.” Hodo v. State, 272 Ga. 272, 528 S.E.2d 250 (March 27, 2000). No merit to Defendant’s claim that his constitutional right to confrontation was violated when the trial court did not permit him to question the state’s witness about the potential sentence the witness could face because of the criminal conduct he had admitted on the stand. Defendant was permitted to ask the witness if he realized that he could be prosecuted and to repeatedly question the witness about any benefit he expected to receive in exchange for his testimony. The mere fact that Defendant was unable to ask the witness to conjecture about possible punishment did not diminish Defendant’s attempt to show the witness’s motive for testifying on behalf of the state , and did not amount to an abuse of the trial court’s discretion. Accord, Jackson v. State , 284 Ga.App. 619, 644 S.E.2d 491 (March 28, 2007); Jackson v. State , 294 Ga. 34, 751 S.E.2d 63 (November 4, 2013); New case!Cheley v. State , S16G0003, ___ Ga. ___, ___ S.E.2d ___, 2016 WL 2946385 (May 23, 2016). McWhorter v. State, 271 Ga. 461, 519 S.E.2d 903 (September 13, 1999). Murder and armed robbery convictions affirmed. “‘A subsequent disposition of a witness' case does not alone prove the existence of a “deal.” [Cit.]’ McLemore v. State, 255 Ga. 107, 108, 335 S.E.2d 558 (1985).” Kenney v. State, 236 Ga.App. 359, 511 S.E.2d 923 (February 9, 1999). Armed robbery convictions affirmed. Trial court did not abuse discretion in allowing defendant to cross examine his accomplice-turned-state’s-witness about maximum sentence he faced, but not minimum. “The trial court allowed defense counsel to fully explore whether the witness had struck a deal with the prosecution in exchange for his testimony or whether he had any other bias that might affect his testimony.” 4. DEFENDANT McNeal v. State, 289 Ga. 711, 715 S.E.2d 95 (September 12, 2011). Malice murder and related convictions affirmed; when defendant was asked on direct “whether [he had] had any encounters with the law” and only testified about one incident, State was properly allowed to impeach him by reading “[his] entire criminal history into evidence.” “At trial, the entire basis of the court's ruling in admitting this evidence was the assertion by the prosecutor that McNeal had lied on the stand and that the prosecutor had the right to disprove that lie. This falls squarely within the purview of OCGA § 24–9– 82.” Brooks v. State, 285 Ga. 246, 674 S.E.2d 871 (March 9, 2009). Malice murder and related convictions affirmed. Trial counsel properly advised defendant that, if he testified, he could be impeached with his prior convictions; under OCGA § 24-9-84.1, enacted in 2005, defendant may be impeached with prior convictions without first placing his character in issue. Chandler v. State, 281 Ga. 712, 642 S.E.2d 646 (March 19, 2007). Malice murder and related convictions affirmed. “The Criminal Justice Act of 2005 also expanded the State’s ability to impeach a defendant who testifies at his trial beyond that which existed at the time of Chandler’s crimes. See OCGA § 24-9-20(b), 24-9-84, 24-9-84.1; Ga. L.2005, p. 20, §§ 14, 16. This modification simply alters the scope of evidence which may be presented at trial. It does not make into a crime an act that was innocent when it was performed, change the manner or degree of punishment to which Chandler may be
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