Wood v. State

Bobby Wood Jr. shot and killed Aaron Skinner outside his Baldwin County home in March 2020, then called 911 himself. A jury convicted him of felony murder and aggravated assault, rejecting his claim of self-defense, and the trial court sentenced him to life with the possibility of parole. On appeal, Wood argued the trial judge wrongly blocked him from cross-examining a ballistics expert about Skinner's prior arrest, wrongly refused to let a defense expert examine physical evidence after trial, and that his trial lawyer was ineffective for not objecting to certain testimony about Skinner's clean criminal record. He also argued these problems added up to deny him a fair trial. The Supreme Court of Georgia rejected every argument. It found that even assuming some mistakes occurred, the evidence against Wood's self-defense claim, including his own statements that he was unsure whether Skinner had a gun and that Skinner never entered his property, was strong enough that none of the claimed errors changed the outcome.

The court held that even assuming the trial court erred in limiting cross-examination and that trial counsel was deficient, none of these assumed errors, individually or combined, created a reasonable probability of a different outcome given the strong evidence undermining Wood's self-defense claim, so the conviction stands.

The ruling shows Georgia courts will uphold convictions even when evidentiary or counsel mistakes are assumed, so long as the overall proof of guilt is strong. It also limits when defendants can get post-trial access to physical evidence to build ineffective-assistance claims.

Affirmed

1. The court applied the harmless-error standard for non-constitutional evidentiary mistakes, which asks whether it is highly probable the error did not affect the verdict, and found that even if the trial court wrongly blocked cross-examination about Skinner's arrest, the strong evidence against self-defense made any error harmless.
2. On the due-process claim about post-trial access to physical evidence, the court applied the rule that a defendant must show favorable test results would likely have changed the trial's outcome, and found Wood's own statements that the bullet 'hit the road' undercut his theory that testing would help him.
3. For the ineffective-assistance claim, the court used the two-part Strickland test (deficient performance plus resulting prejudice) and found that even assuming counsel was deficient in not objecting to testimony about the victim's clean record, Wood could not show a reasonable probability of a different result.
4. Applying the cumulative-error doctrine, which asks whether multiple assumed errors together denied a fundamentally fair trial, the court concluded the combined effect of the assumed errors still did not overcome the strong evidence contradicting Wood's self-defense claim, including that the victim never entered his property and that Wood was unsure whether the victim had a gun.

• felony murder conviction
• self-defense claim
• ineffective assistance of counsel
• cross-examination limits
• Baldwin County shooting