☢ test - Í

Givens v. State, 281 Ga.App. 370, 372(2) (636 S.E.2d 94) (2006).” Carpenter v. State, 285 Ga.App. 296, 645 S.E.2d 709 (May 8, 2007). No ineffective assistance for failure to challenge voluntariness of defendant’s statement where “the videotaped statement was consistent with the defense’s theory of justification.” Thus, “[e]ven if the statement could have been excluded, … we hold that the performance of Carpenter’s trial counsel was not deficient.” See also Felton (February 25, 2008), above. Parker v. State, 281 Ga. 490, 640 S.E.2d 44 (January 8, 2007). “It is asserted that trial counsel was ineffective in failing to object to the admissibility of Parker’s statements to the police. Trial counsel testified at the hearing on the motion for new trial that he anticipated Parker would testify in his own defense and when he did, the statements would be admissible for purposes of impeachment. See Harris v. New York, 401 U.S. 222 (91 S.Ct. 643, 28 L.Ed.2d 1) (1971) (voluntary statement which fails to comply with Miranda is admissible for impeachment purposes); Dampier v. State, 245 Ga. 427(15) (265 S.E.2d 565) (1980). Thus, counsel’s decision not to challenge the admissibility of the statements was a reasonable strategic decision.” Defendant did, in fact, testify. Query: Does the result change if defendant later decides not to testify? Lowe v. State, 259 Ga.App. 674, 578 S.E.2d 284 (February 14, 2003). Failure to request a Jackson-Denno hearing regarding admissibility of statement of borderline-retarded defendant is not per se ineffective assistance of counsel, where statement was exculpatory and consistent with defense presented at trial. Johnson v. State, 236 Ga.App. 61, 510 S.E.2d 918 (January 21, 1999). “The lack of a Jackson-Denno hearing is not prejudicial per se, and counsel may, in appropriate circumstances, engage in a reasonable trial strategy to forgo such a hearing. See, e.g., Hightower v. State, 227 Ga.App. 74, 79(d), 487 S.E.2d 646 (1997) (physical precedent only).” See also Felton (February 25, 2008), above. 59. JURORS, SEQUESTRATION Williams v. State, 286 Ga. 884, 692 S.E.2d 374 (March 29, 2010). In defendant’s capital murder trial, no ineffective assistance where “counsel failed to insist on sequestering the jury.” “At the hearing on the motion for new trial, counsel testified that he believed it was preferable in this case to permit the jurors to disperse and allow each person to interpret the day's evidence individually rather than combining ‘into a one man jury.’ Counsel chose this strategy after conferring with staff in the Capital Defenders program as well as with his client, because counsel thought it would give the jurors a more diverse perspective on the evidence thereby increasing the likelihood of a hung jury or an acquittal. We find this to be a reasonable tactical decision on counsel's part.” 60. JURY CHARGES – REQUESTING/FAILURE TO REQUEST/FAILURE TO OBJECT King v. State, A15A1878, ___ Ga.App. ___, 784 S.E.2d 875, 2016 WL 1237321 (March 30, 2016). Armed robbery and related convictions affirmed; no ineffective assistance in requesting a pattern jury charge later ruled improper. Charge here: pattern charge on witness identification of defendant, including consideration of “witness’s level of certainty,” which was later ruled out in Brodes v. State, 279 Ga. 435, 614 S.E.2d 766 (2005). “‘There is no general duty on the part of defense counsel to anticipate changes in the law....’ (Citations, punctuation and footnote omitted.) Rickman v. State, 277 Ga. 277, 280(2), 587 S.E.2d 596 (2003). … After examining trial counsel’s perspective at the time of trial, including the fact that the requested charge was then a pattern jury instruction, we cannot conclude that trial counsel was ineffective for failing to anticipate the Supreme Court’s decision in Brodes, supra.” Barney v. State, 333 Ga.App. 807, 777 S.E.2d 490 (September 15, 2015). Burglary convictions affirmed; no ineffective assistance in failure to request jury charge on accomplice corroboration. “At the motion for new trial hearing, Barney’s trial counsel testified that she *812 did not request a charge for accomplice liability because ‘our theory was that he was not present for the burglary[.]’ [Cit.] ‘ Decisions as to which charges will be requested generally fall within the realm of trial tactics and strategy ... [and] [a]s a general rule, matters of reasonable tactics and strategy, whether wise or unwise, do not amount to ineffective assistance of counsel.’ (Punctuation and footnotes omitted.) White [ v. State, 308 Ga.App. 38, 44(4), 706 S.E.2d 570 (2011).” Summerville v. State, 332 Ga.App. 617, 774 S.E.2d 190 (June 26, 2015). Marijuana trafficking and related convictions affirmed; no ineffective assistance in failure to object to pattern Allen charge. “Summerville argues that the jury charge was impermissibly coercive, but he has not identified any language in the pattern charge that was potentially coercive. See Scott v. State, 290 Ga. 883, 888(6), 725 S.E.2d 305 (2012) (no error when defendant fails to identify any language in pattern or modified Allen charge that was potentially coercive). Although Summerville points to the short