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current charges were domestic in nature, unlike the prior offenses). Williams v. State, 328 Ga.App. 876, 763 S.E.2d 261 (August 26, 2014). Burglary conviction affirmed; under pre-2013 Evidence Code, trial court erred, but harmless, in denying admission of witness’s prior felony conviction for impeachment. State’s witness was convicted of cocaine possession nine years prior to trial; trial court excluded the evidence on grounds “that the probative value of [witness] Curry's prior conviction for possession of cocaine was outweighed by its prejudicial effect and did not require the State to show that such prejudice substantially outweighed any probative value.” OCGA § 24-6-609 admits evidence of prior felony convictions of a witness other than the defendant “subject to the provisions of Code Section 24–4–403.” OCGA § 24-4-403 provides for the admission of relevant evidence generally unless “its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury or by considerations of undue delay, waste of time, or needless presentation of cumulative evidence.” Thus, trial court used the wrong standard to exclude the evidence. Harmless, however, as “Curry testified that he had prior troubles with the law, that he had a criminal record, and that he spent time in prison. Thus, evidence of Curry's criminal history – albeit unspecific – was presented to the jury. In fact, Curry's own testimony arguably damaged his credibility far more than Williams would have done by being limited to merely introducing the record of Curry's prior conviction [fn] for possession of cocaine.[fn] Consequently, at most, the admission of Curry's prior conviction would have been cumulative of his own damaging testimony.” Johnson v. State, 328 Ga.App. 702, 760 S.E.2d 682 (July 15, 2014). Whole court opinion. Rape conviction affirmed; under pre-2013 Evidence Code, no abuse of discretion in admitting prior conviction more than 10 years old. “Here, although the trial court did not make such an on-the-record finding during the trial , it entered an order after sentencing, specifically indicating therein that it considered the five factors set forth in Clay. The court concluded that given the nature of the charges in this case and the fact that the credibility of the victim and the defendant were central to the issues, the probative value of the terroristic threats conviction substantially outweighed any prejudicial effect. The trial court also noted that although the State also sought to introduce two other more ‘serious’ convictions that were older than ten years, the trial court decided to admit only the terroristic threats conviction in order to limit the risk of prejudice to Johnson. Under these circumstances, we find no abuse of discretion in the trial court's admission of the prior terroristic threats conviction for impeachment purposes. See McNabb v. State, 292 Ga.App. 395, 397–398(1), 664 S.E.2d 800 (2008).” Hudson v. State, 325 Ga.App. 810, 755 S.E.2d 209 (February 24, 2014). Theft by taking conviction affirmed; under pre- 2013 Evidence Code, no ineffective assistance in “failing to object to the State impeaching Hudson without certified copies of the convictions. ‘It is well-settled that evidence of a witness' prior convictions must be tendered and admitted in the form of certified copies of the convictions and not by testimony alone.’ (Citations omitted.) Rucker v. State, 205 Ga.App. 651 (423 S.E.2d 51) (1992). However, ‘[t]he failure to introduce a certified copy of an impeaching prior conviction is subject to a “best evidence” objection ... and such objection may be waived.’ (Citation omitted.) Thomas v. State, 268 Ga. 135, 140(13) (485 S.E.2d 783) (1997). Thus, ‘in the absence of a “best evidence” objection, a witness' answer to the effect that he or she has been convicted of a crime is admissible to prove the crime.’ (Citations omitted.) McIntyre v. State, 266 Ga. 7, 10(4) (463 S.E.2d 476) (1995). Even if we assume that Hudson's trial counsel was ineffective for failing to object to the State's attempts to impeach him without a certified copy of the conviction, he has not proven that such failure was prejudicial to his defense. The convictions the State sought to impeach Hudson with were either already addressed by him during his direct examination or were his brother's convictions and the trial court properly instructed the jury to disregard questions about them.” Crosby v. State, 319 Ga.App. 459, 735 S.E.2d 588 (December 17, 2012). Physical precedent only. Burglary and related convictions affirmed; trial court erred, but harmless, in allowing impeachment of defendant with prior felony conviction without “mak[ing] an on-the-record finding that the probative value … substantially outweighs its prejudicial effect,” citing Clay v. State , 290 Ga. 822, 725 S.E.2d 260 (March 19, 2012). “In this case, after hearing argument from both parties as to whether the probative value of the conviction outweighed the prejudicial effect, the trial court simply stated that the conviction would be admitted for impeachment purposes without further explanation. Thus, we cannot determine whether the trial court in this case ‘engaged in any meaningful analysis of the relevant factors or whether the court balanced the probative value against the prejudicial effect to the accused.’ Quiroz [ v. State, 291 Ga.App. 423, 428-429(4) (662 S.E.2d 235) (2008)] (punctuation omitted). Accordingly, we are constrained to find that the trial court erred. See Lawrence [ v. State, 305 Ga.App. 199, 203(3) (699 S.E.2d 406) (2010)] (holding that trial court's failure to comply with requirements of OCGA § 24–9–84.1(a)(2) was harmless given that inculpatory evidence against defendant was overwhelming).” Harmless, however, in light of overwhelming evidence of guilt. Accord, Johnson v. State , 328 Ga.App. 702, 760 S.E.2d 682 (July 15, 2014) (whole court opinion).