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with that evidence on cross-examination.” “At the hearing on Douglas's motion for new trial, his trial counsel testified that Douglas's theory of defense was mistaken identity, and agreed that the case ‘hinged on the credibility of the three victims.’ When asked whether she had reviewed the victims' criminal history, counsel replied that while it was her policy to run a criminal background check and ask her investigator to see if there were any criminal charges pending, she apparently had not done so in this case or she would have cross-examined them about their prior convictions.” Adequate investigation also would have showed that the victims had been arrested together on two occasions, and two of them had pending charges when they testified against defendant. “[O]ther than identification of Douglas by a witness who lost sight of the robber while chasing him and by the victims following a one-on-one showup in the back of a police car two hours after the robbery,[fn] no other evidence ties Douglas to the crimes.” Humphrey v. Williams, 295 Ga. 536, 761 S.E.2d 297 (July 11, 2014). Following conviction for child molestation, habeas court properly granted relief based on ineffective assistance. 1. Trial counsel was ineffective for failure to obtain readily available court records related to similar transaction, which would have shown that the alleged victim’s credibility was completely discredited. Trial counsel failed to obtain the records despite being aware of the evidence and its importance in this case, which was based entirely on victim credibility. The allegations of molestation were made years after the fact, with no other witnesses and no forensic evidence. “Based on what Williams (and later other witnesses) told him, [defense counsel] Grantham believed that the Florida Court had concluded that the alleged similar transaction in 1993 never happened and that the court had ordered (alleged prior victim] Jessica to be returned to Williams's custody. Grantham, however, made no effort whatsoever to investigate the documentary basis for that judicial decision, although any competent lawyer knows that courts produce documents reflecting (and usually explaining) such decisions. The filings in the 1993 Florida Court case regarding Jessica presented an obvious source of information and evidence for presentation at the similar transaction hearing to try to exclude her testimony altogether and for impeachment if Jessica was allowed to testify at trial. As the habeas court explained, the Florida Court records would have given the trial court and the jury something to corroborate the witnesses, something beyond the ‘he said, she said’ accounts of the 1993 events. [fn] Moreover, those Florida records from Gadsden County, directly across the state line from Decatur County, were readily available, as revealed by the fact that Williams—operating pro se and from a Georgia prison—was able to obtain them with little difficulty.” Citing Rompilla v. Beard, 545 U.S. 374, 125 S.Ct. 2456, 162 L.Ed.2d 360 (2005) (“defendant's trial counsel were deficient for failing to obtain a readily available court file on a similar prior offense by their client, which counsel knew the prosecution planned to rely on at a death penalty sentencing hearing. See id. at 383–390. The Court noted that ‘[n]o reasonable lawyer would forgo examination of the file thinking he could do as well by asking the defendant or family relations whether they recalled anything helpful or damaging in the prior victim's testimony.’ Id. at 389.”) and Head v. Taylor, 273 Ga. 69, 82, 538 S.E.2d 416 (2000) (“trial counsel were deficient in failing to obtain readily available jail records to disprove an anticipated prosecution claim that the defendant's behavior in jail was normal, where counsel were on notice from their own observations of the defendant and a letter he sent to one of them that he was exhibiting signs of mental illness while in jail.”). Distinguishing “ Head v. Hill, 277 Ga. 255, 267, 587 S.E.2d 613 (2003) (holding that trial counsel reasonably abandoned their efforts to obtain certain school records after making repeated requests for the records and after being advised, as was the trial court, that no further records existed).” 2. Counsel’s deficient performance prejudiced defendant, as the absence of the records enabled the prosecutor to falsely represent the outcome of the matter to the jury. Also, the account of the alleged incident related in the records was dramatically different from the witness’s testimony at defendant’s trial in this case. Leopold v. State, 324 Ga.App. 550, 751 S.E.2d 184 (November 7, 2013). Following defendant’s marijuana possession and possession with intent to distribute, 1. trial court properly found no ineffective assistance in counsel’s failure to impeach State’s witness with convictions, not involving dishonesty, more than ten years old. “The record shows that all of the felony convictions were more than ten years old, that the trial court would not have abused its discretion by concluding that the probative value of these convictions did not outweigh their prejudicial effect, and that none of the misdemeanor convictions involved fraud or deceit. See former OCGA § 24–9–84.1(a)(2) and (3) and (b). ‘Because [Leopold] has failed to establish that the convictions would have been admitted, he has not shown that his lawyer[ ] [was ineffective]’ on this ground. Williams v. State, 292 Ga. 844, 852(3)(e), 742 S.E.2d 445 (2013) (rejecting ineffective assistance claim based on failure to impeach with prior convictions because trial court would not have abused discretion in denying use of convictions). See also Boatright v. State, 308 Ga.App. 266, 271(1)(c), 707 S.E.2d 158 (2011).” 2. Counsel wasn’t ineffective for failing to impeach witness in every way available – in this case, his two years as a fugitive following this incident. “‘The scope of cross-examination is grounded in trial tactics and strategy, and will rarely constitute ineffective assistance of counsel.’ (Citation and footnote omitted.) Kelley v. State, 295 Ga.App. 663, 668(2)(d), 673 S.E.2d 63 (2009). And ‘[a] claim of ineffective assistance of counsel is judged by whether counsel rendered reasonably effective assistance, not by a standard of errorless counsel or by hindsight.’ Hooks v. State, 280 Ga. 164, 165(3), 626

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