basis of an ineffectiveness claim (Georgia) · Go Syfert
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basis of an ineffectiveness claim in Georgia

11 Georgia opinions name it 2 courts 2022–2026 11 in the last five years

The cases below were cited by Georgia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Warren v. Stategreen
ga · 2022 · cited in 7 Georgia opinions naming this issue, 2024–2026
2 sentences

2026In alleging ineffective assistance of counsel, Tritt bears the burden of showing that “no reasonable lawyer would have done what his lawyer did, or would have failed to do what his lawyer did not.” Ryals v. State, 321 Ga. 151, 156 (1) ( 913 SE2d 604 ) (2025) (citation omitted). “[C]ounsel’s decisions about trial tactics and strategy in particular may not form the basis of an ineffectiveness claim unless they were ‘so patently unreasonable that no competent attorney would have followed such a course.’” Warren v. State, 314 Ga. 598, 602 (2) ( 878 SE2d 438 ) (2022) 29 (citation omitted).

2026In alleging ineffective assistance of counsel, Tritt bears the burden of showing that “no reasonable lawyer would have done what his lawyer did, or would have failed to do what his lawyer did not.” Ryals v. State, 321 Ga. 151, 156 (1) ( 913 SE2d 604 ) (2025) (citation omitted). “[C]ounsel’s decisions about trial tactics and strategy in particular may not form the basis of an ineffectiveness claim unless they were ‘so patently unreasonable that no competent attorney would have followed such a course.’” Warren v. State, 314 Ga. 598, 602 (2) ( 878 SE2d 438 ) (2022) 29 (citation omitted).

77
Washington v. Stategreen
ga · 2022 · cited in 2 Georgia opinions naming this issue, 2022–2022
2 sentences

2022And counsel’s decisions about trial tactics and strategy in particular may not form the basis of an ineffectiveness claim unless those decisions were “so patently unreasonable that no competent attorney would have followed such a course.” Id. (citation and punctuation omitted).

2022And counsel’s decisions about trial tactics and strategy in particular may not form the basis of an ineffectiveness claim unless those decisions were “so patently unreasonable that no competent attorney would have followed such a course.” Id. (citation omitted).

22
Ryals v. Stategreen
ga · 2025 · cited in 1 Georgia opinions naming this issue, 2026–2026
1 sentence

2026In alleging ineffective assistance of counsel, Tritt bears the burden of showing that “no reasonable lawyer would have done what his lawyer did, or would have failed to do what his lawyer did not.” Ryals v. State, 321 Ga. 151, 156 (1) ( 913 SE2d 604 ) (2025) (citation omitted). “[C]ounsel’s decisions about trial tactics and strategy in particular may not form the basis of an ineffectiveness claim unless they were ‘so patently unreasonable that no competent attorney would have followed such a course.’” Warren v. State, 314 Ga. 598, 602 (2) ( 878 SE2d 438 ) (2022) 29 (citation omitted).

11
Burton v. Stategreen
ga · 1994 · cited in 1 Georgia opinions naming this issue, 2024–2024
2 sentences

2024“In Georgia, whether or not to testify in one’s own defense is considered a tactical decision to be made by the defendant himself after consultation with his trial counsel[.]” Burton v. State, 263 Ga. 725, 728 (6) (438 SE2d 83) (1994) (citations omitted).

2024“In Georgia, whether or not to testify in one’s own defense is considered a tactical decision to be made by the defendant himself after consultation with his trial counsel[.]” Burton v. State, 263 Ga. 725, 728 (6) (438 SE2d 83) (1994) (citations omitted).

11
Dye v. Stategreen
gactapp · 2004 · cited in 1 Georgia opinions naming this issue, 2024–2024
2 sentences

2024Accordingly, Page is merely speculating that the juror was biased against him, and “speculation cannot serve as the basis of an ineffectiveness claim.” Dye v. State, 266 Ga. App. 825, 827 (2) (a) ( 598 SE2d 95 ) (2004) (citation and punctuation omitted). (b) Page argues that his trial counsel was ineffective for failing to object to a line of questioning in which the victim’s aunt was asked about the impact the victim’s disclosure had on the family.

2024Accordingly, Page is merely speculating that the juror was biased against him, and “speculation cannot serve as the basis of an ineffectiveness claim.” Dye v. State, 266 Ga. App. 825, 827 (2) (a) ( 598 SE2d 95 ) (2004) (citation and punctuation omitted). (b) Page argues that his trial counsel was ineffective for failing to object to a line of questioning in which the victim’s aunt was asked about the impact the victim’s disclosure had on the family.

11
Zayas v. Stategreen
ga · 2024 · cited in 1 Georgia opinions naming this issue, 2024–2024
2 sentences

2024To show prejudice, Jiles “must show that there is a reasonable probability that, but for counsel’s deficiency, the result of the trial would have been different.” Zayas v. State, 319 Ga. 402, 409 (3) (902 SE2d 583) (2024) (citation and punctuation omitted).

2024To show prejudice, Jiles “must show that there is a reasonable probability that, but for counsel’s deficiency, the result of the trial would have been different.” Zayas v. State, 319 Ga. 402, 409 (3) (902 SE2d 583) (2024) (citation and punctuation omitted).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Georgia. Read the followed side critically anyway.

Also cited on this issue (1)

CaseCitedYears
Strickland v. Washington green
scotus · 1984
2 sentences

2022And counsel’s decisions about trial tactics and strategy in particular may not form the basis of an ineffectiveness claim unless they were “so patently unreasonable that no competent attorney would have followed such a course.” Id. (citation omitted).

2022And counsel’s decisions about trial tactics and strategy in particular may not form the basis of an ineffectiveness claim unless they were “so patently unreasonable that no competent attorney would have followed such a course.” Id. (citation omitted).

52022–2026

Statutes the citing opinions construe

GA § 24-14-8 (5) GA § 24-14-6 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

GA 11 (2022–2026) PA 6 (1995–2018) IL 3 (1991–2024) MI 2 (2016–2018) MO 2 (1990–1991) ME 2 (2021–2021)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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