Georgia v. GarlandAnnotate this Case
Appellee Steven Lee Garland was convicted of sexual battery involving a child and sentenced to serve one year imprisonment followed by four years of probation. His conviction was affirmed on appeal. Garland filed a petition for writ of habeas corpus which the habeas court granted based on its determination that Garland’s appellate counsel provided ineffective assistance. The habeas found as a matter of fact that Garland did not consent to an agreement with the State and that trial counsel did not investigate Garland’s mental health history. Had trial counsel properly investigated, the habeas court determined, he would have discovered evidence showing that Garland was not competent to stand trial and that his mental condition likely would have been a defense to criminal liability. The State appealed the order granting Garland habeas relief, but finding no reversible error, the Supreme Court affirmed.