MADERA v. THE STATE
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In a case before the Supreme Court of Georgia, Francisco Javier Madera, who was convicted of the murder of Juan Carlos Zambrano, appealed his conviction on five grounds. He argued that the trial court erred by denying his motion for a new trial; admitting video footage of the injured victim; admitting evidence under OCGA § 24-8-803 (5); his counsel was ineffective; and the cumulative effect of the errors required a new trial.
Madera was found guilty of malice murder, felony murder, and aggravated assault. After a physical altercation at a party, Madera shot Zambrano, who was unarmed. Madera claimed he acted in self-defense, but the State presented evidence that no weapons were found on Zambrano.
The court upheld Madera's conviction, rejecting all five claims of error. Madera’s arguments on the admission of evidence were reviewed for plain error as they were not objected to at the trial. The court found no plain error or any showing that the errors affected his substantial rights. The court also upheld the denial of his motion for a new trial, noting that the decision is vested solely in the trial court and is not subject to review.
Madera’s claim of ineffective assistance of counsel was rejected. He failed to show how further investigation would have revealed additional evidence or how it would have helped his defense. His disagreement with his counsel’s strategy to not file a pre-trial immunity motion did not mean the strategy was objectively unreasonable. Madera’s claim of cumulative error also failed as no trial court error was identified.
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