Mangrum v. Georgia
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In December 2005, Appellant Jamerson Mangrum was found guilty of numerous crimes related to the death of 15-year-old Katie Hamlin in July 2002, including three counts of felony murder, two counts of aggravated child molestation, and one count each of rape, abandoning a dead body, concealing a death, and tampering with evidence. After his motion for new trial was denied, Appellant obtained new counsel and appealed to the Supreme Court, alleging numerous grounds for reversal. In its first review of this case, the Court rejected all of his arguments except for his claim of ineffective assistance of trial counsel, which was remanded to the trial court for a hearing. In 2011, the trial court held a hearing on the ineffective assistance claim. The only witness at the hearing was Appellant's trial counsel, Jimmy Berry. At the hearing, Appellant's new counsel attempted to show that Berry unreasonably failed to support his theory that the victim's medications caused her to have a seizure and asphyxiate and to investigate the possibility that her failure to take her medications caused her death. However, new counsel did not offer any of the victim's medical records or present any expert medical testimony at the hearing. The the trial court denied Appellant's ineffective assistance claim. He appealed that ruling. Upon review, the Supreme Court found that Appellant was required to offer more than "mere speculation" that the victim's medical records and expert testimony would have bolstered his defense at trial for his ineffectiveness claim. He failed to do so, offering no evidence at the hearing as to the victim's medical records or how their introduction or the introduction of testimony about them would have changed the outcome of his trial. Appellant therefore failed to establish ineffective assistance of counsel, and the trial court correctly denied his claim.
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