In the Supreme Court of Georgia

Decided: July 5, 2023

S23A0637. WOOD v. THE STATE

 COLVIN, Justice.

Appellant Bobby Wood, Jr., was convicted of felony murder in 

connection with the March 2020 shooting death of Aaron Skinner.1

On appeal, Appellant contends that (1) the trial court abused its 

discretion in denying him the opportunity to cross-examine the 

 1 Skinner died on March 30, 2020. On November 6, 2020, a Baldwin 

County grand jury indicted Appellant for malice murder (Count 1), felony 

murder predicated on aggravated assault (Count 2), and aggravated assault 

(Count 3). On April 16, 2021, Appellant moved for immunity from prosecution 

based on self-defense under OCGA § 16-3-24.2. After a hearing, the trial court 

denied the immunity motion. At a jury trial held May 10 to 12, 2021, the jury 

found Appellant not guilty of malice murder but guilty of felony murder and 

aggravated assault. The trial court sentenced Appellant to life in prison with 

the possibility of parole for the felony murder count and merged the underlying 

aggravated assault count into the felony murder conviction for sentencing 

purposes. Appellant’s trial counsel timely filed a motion for new trial on May 

14, 2021, which was subsequently amended through new counsel on September 

14, 2022. After a hearing, the trial court denied the amended motion on 

September 29, 2022. Appellant filed a timely notice of appeal. The case was 

docketed to this Court’s April 2023 term, and oral argument was held on May 

18, 2023. 
2

State’s expert witness about Skinner’s alleged arrest for criminal 

trespass on the day before the shooting; (2) the trial court violated 

his right to due process by denying him access to certain physical 

evidence post-trial; (3) trial counsel was ineffective for failing to 

object to the State’s redirect examination of the State’s expert

witness as outside the scope of redirect examination; and (4) the 

cumulative effect of the alleged errors committed by the trial court

and trial counsel deprived Appellant of a fair trial. For the reasons 

set forth below, we affirm. 

1. The evidence at trial showed the following.2 Around 9:00 

p.m. on March 30, 2020, officers with the Baldwin County Sheriff’s 

Office were dispatched to Fox Hill Road after a 911 caller reported 

 2 Because this case involves questions of harmless error and prejudice 

under Strickland v. Washington, 466 U.S. 668 (104 SCt 2052, 80 LE2d 674)

(1984), the trial evidence is described in some detail rather than only in the 

light most favorable to the jury’s verdicts. See Ash v. State, 312 Ga. 771, 772 

(1) n.2 (865 SE2d 150) (2021) (noting that when assessing whether a trial-court 

error was harmless, “we review the evidence de novo and weigh it as a 

reasonable juror would, rather than reviewing it in a light most favorable to 

upholding the jury’s verdicts of guilty” (citation and punctuation omitted)). See

also Draughn v. State, 311 Ga. 378, 382-383 (2) (b) (858 SE2d 8) (2021) (“To 

determine whether [a defendant] has shown Strickland prejudice, we review 

the record de novo and weigh the evidence as we would expect reasonable 

jurors to have done.” (citation and punctuation omitted)).
3

seeing “a suspicious person.” As an officer was en route to the area, 

officers received a second 911 call from Appellant reporting that “a 

man was shot” on Fox Hill Road. In response to the 911 operator’s 

questions, Appellant revealed that he “shot [the man] . . . with a 

rifle.” Appellant further stated that the man, who he identified as 

his sister’s ex-boyfriend, was “coming at [him]” and “pointing a gun 

at [him] or something and talking real crazy.”

Upon arriving on the scene, officers found the man “lying on 

the ground . . . [i]n the middle of the road” with a “[g]unshot wound 

to the lower stomach area.” There were no weapons on or near his 

body. Officers were able to identify the man as Skinner based on his 

photo in the jail database system. Appellant was still at the scene 

and, when asked, immediately identified himself as the shooter, 

explaining that Skinner “came at [him], pointing something.” Upon 

request, Appellant led the officers to his car, where he had placed 

the firearm used to shoot Skinner, which was an AK 7.62 x 39 

firearm with “two magazines that were taped together.”
4

Appellant waived his Miranda rights3 and consented to be 

interviewed by Detective Michael Burrell on the scene. Appellant 

informed Detective Burrell that his sister, Sheila Wood (“Sheila”), 

had dated Skinner over a year ago and that he “met [Skinner] a few 

times and didn’t like him.” According to Appellant, Sheila and 

Skinner had not had any contact in the past year, until Skinner 

showed up at Sheila’s house around midnight on the night before 

the shooting. Appellant had been visiting Sheila at the time, but did 

not speak with Skinner. Appellant further stated that, right before 

the shooting, he was inside his house when he received a Facebook 

message from his neighbor, Jessica Driggers, informing him that 

Skinner was “geeked out” and Skinner was on his way to Appellant’s 

house. Appellant went to his car, which was parked next to his 

house, to grab his firearm and other belongings because, according 

to Appellant, Skinner was a “thief,” and had stolen pistols from him 

and Sheila in the past. Appellant then heard his roommate, Keith 

Blizard, who was driving away from Appellant’s house but still 

 3 Miranda v. Arizona, 384 U.S. 436 (86 SCt 1602, 16 LE2d 694) (1966).
5

within earshot, tell someone “to leave,” and Appellant saw Skinner 

walking on the road toward his house. Appellant told Skinner to

“stop” and fired three warning shots from inside his fenced-in yard. 

Appellant explained that he fired these warning shots at a ditch 

near where Skinner was standing, which was between his threefoot, barbed-wire fence and the roadway, and that Skinner 

continued to “come at [him]” while “talking out of his head.” 

Appellant stated that he fired one more shot in Skinner’s direction, 

saw “sparks like [the bullet] hit the road,” and heard Skinner 

“holler.” Appellant explained that he thought Skinner left the area 

after the fourth shot, so he went inside his house to retrieve his 

phone and a flashlight and then got into his car because he was 

“fixing to see where [Skinner] went.” Appellant then saw Skinner 

lying in the road and called 911. Throughout the interview, which 

was recorded on the body camera of one of the responding officers, 

Appellant maintained that he “thought [he] was in danger of 

[Skinner] hurting him” but that he was unsure whether Skinner was 

actually pointing a gun because “it was dark.” Appellant also 
6

showed Detective Burrell where he was standing in relation to the 

ditch and Skinner, and Detective Burrell confirmed with Appellant 

that Skinner never entered his driveway or yard. 

On the morning after the shooting, officers went back to

investigate the scene, which was left unsecured overnight. Officers

observed three bullet strikes in the ditch area. Officers also 

observed four additional bullet strikes outside of the ditch and in the 

road and general area. Further, the officers found in the general 

area a total of seven shell casings and were able to recover two 

bullets. Although the State’s ballistic expert testified that the shell 

casings visually “matched the bullets that were in the magazines” 

seized from Appellant, no further ballistic testing was performed.

A search of Appellant’s cell phone confirmed his statement that 

he had received a Facebook message from Driggers right before the 

shooting. Appellant’s cell phone further revealed that he had the 

following conversation with Sheila on Facebook Messenger at 9:12 

p.m. on the night of the shooting: 

APPELLANT: I shot Aaron so go on to sleep 
7

SHEILA: Seriously? I saw him walking up 49 today and 

[J]essica just said that he keeps coming by there.[4]

APPELLANT: Seriously

SHEILA: Is he dead? [J]essica told me his dumb a** was 

headed to you. He must have been tweaking bad 

SHEILA: She said he going on about me. I haven’t talked 

to him in over a year till he popped up. I heard cops 

hauled him off from his mama’s yesterday [so] he must’ve 

come this way? 

APPELLANT: Well [K]eith told [him] he better leave and 

he was talking crazy I told him he better get up road and 

he started at me pointing something I shot he hit ground 

started hollering he loved me I didn’t know if it was a gun 

or what so I shot

Appellant’s cell phone records further revealed that he had called 

911 at 9:22 p.m., approximately ten minutes after he first messaged 

Sheila. 

Detective Burrell interviewed Appellant two additional times, 

both of which were video-recorded. Throughout the interviews, 

Appellant maintained that he “didn’t know if [Skinner] had a gun or 

not so [he] shot him,” and he stated that he had heard from Sheila 

 4 Sheila then sent Appellant a “thumbs up” icon. 
8

that Skinner was recently in jail. When Detective Burrell revealed 

to Appellant that officers found a total of seven shell casings, 

Appellant responded that he thought he had only fired four shots. 

Detective Burrell also asked Appellant why it had taken him ten

minutes to call 911 after messaging Sheila. Appellant responded 

that he was trying to find a flashlight. During the final interview, 

Detective Burrell asked Appellant if he had fired a few shots before

he saw Skinner raise his hand and point in Appellant’s direction, 

and Appellant responded, “Yeah.” 

At trial, the jury viewed video recordings of Appellant’s three 

interviews and body camera footage of the officers who first arrived 

on the scene. Detective Burrell testified that his investigation 

revealed that Skinner had never entered Appellant’s property; that 

Appellant began shooting toward Skinner from behind his fence 

before he saw Skinner raise his hand and point something at 

Appellant; that, when asked if Appellant knew what Skinner was 

pointing, Appellant stated that he “d[id]n’t have a clue, it was dark”; 

and that Appellant never stated during his interviews that Skinner 
9

verbally threatened him. 

The State’s ballistic expert, Major Joseph Bradley King, 

testified that, based on the “cluster of shell casings” found, the 

shooter fired a total of seven shots from a stationary position. He 

further opined that the fatal bullet ricocheted off the roadway before 

hitting Skinner and that it was unlikely that Skinner “would have 

traveled far [after being hit with the bullet] because he was injured 

pretty bad,” indicating that Skinner had been moving away from the 

ditch and back toward the road when he was shot. On crossexamination, Major King was asked about his decision to leave the 

crime scene unsecured on the night of the shooting and whether it 

was possible that someone tampered with the evidence. Major King 

maintained that it was “unlikely” and that he “[stood] by [his] 

decision” to leave the scene unsecured. 

The State called Blizard, Sheila, and Driggers as witnesses. 

Blizard testified that, shortly before the shooting, he saw Skinner 

walking down the road toward Appellant’s house. According to 

Blizard, Skinner looked like “something was wrong with him,” and 
10

Blizard could “tell he was messed up on something.” Blizard 

testified that he told Skinner to go back the other way because he 

“kn[e]w through [Appellant]” that Skinner was “a thief.” 

Sheila testified that Skinner came to her house around 

midnight on March 29, that he appeared to be intoxicated, and that 

he left after she asked him to leave. Sheila also testified that she 

saw Skinner again at 4:00 p.m. on the day of the shooting. Skinner 

was walking down the highway and again appeared to be

intoxicated. Sheila further testified that Skinner was “sweet” and

“[v]ery attentive” when he was sober. But she said that, when he 

was intoxicated, “[h]e was very abusive verbally, sometimes 

physically abusive,” and that, “if he had been up for a few days, he 

tended to be more violent.” Sheila also stated that, while she and 

Skinner were dating, she believed Skinner may have stolen 

Appellant’s gun out of his truck. 

Driggers testified that Skinner knocked on her door shortly 

before 9:00 on the night of the shooting and was “just babbling 

incoherently.” Driggers further testified that she had seen him “a 
11

little high before,” but that “this time [she] felt like he was really out 

there on something.” Driggers also stated that Skinner had not 

threatened her but made her feel “uneasy” and that Skinner did not 

appear to have any weapons but “did have a lot of things in his 

hands.” 

Additionally, the State called as witnesses two people who were 

driving down Fox Hill Road immediately after the shooting. They 

testified that Appellant had appeared calm and did not seem to be

too “tor[n] up” about what had happened. 

A medical examiner testified that the bullet retrieved from 

Skinner during his autopsy entered at an upward angle and that the 

gunshot wound was “rapidly fatal.” The medical examiner also 

testified that Skinner had methamphetamine, amphetamines, and 

marijuana in his system when he died.

The defense introduced as its sole witness a toxicology expert. 

She testified that, prior to Skinner’s death, he had “very recently” 

used methamphetamine. However, she opined that Skinner “wasn’t 

in a binging situation” and had likely used methamphetamine at 
12

“one setting . . . and then did not use any more.” 

2. Appellant first contends that the trial court abused its 

discretion in denying him the opportunity to cross-examine Major 

King about Skinner’s prior arrest for criminal trespass. Appellant’s 

claim fails.

Before trial, the State moved in limine “to prevent the 

defendant from blatantly attacking the victim’s character.” 

Specifically, the State sought to exclude evidence that, on the day 

before the shooting, Skinner and his mother had an altercation and 

Skinner was arrested for criminal trespass. The trial court ruled 

that, because Appellant did not know about Skinner’s arrest when 

the shooting occurred, the arrest was irrelevant and inadmissible. 

During trial, Appellant twice moved the trial court to reverse 

its previous ruling excluding Skinner’s arrest. First, Appellant 

asked the court to revisit its earlier ruling after the jury viewed 

video footage from the body cameras of Officers Kevin Veal and 

Ashley Brown. The body camera footage showed the officers identify

Skinner based on his photo in the jail database system and discuss
13

that Skinner was “in the jail recently” and had been “locked up for 

criminal trespass,” and Appellant argued that the State had “opened 

the door” to the arrest. The State objected, noting that the 

prosecutor had stopped playing Officer Brown’s body camera footage 

before Skinner’s arrest was mentioned but that defense counsel had 

requested that the entire footage be played for the jury. The trial 

court denied Appellant’s request. Appellant again asked the court 

to reconsider its prior ruling after the following exchange occurred 

during the State’s redirect examination of Major King: 

STATE: This jury this week has heard what an awful 

person Aaron Skinner is or was. During the course of your 

investigation, your team’s investigation, did you look at 

Aaron Skinner’s criminal history? 

MAJOR KING: Yes, sir. 

STATE: How many burglary convictions did Aaron 

Skinner have? 

MAJOR KING: None. 

STATE: How many theft by taking convictions did Aaron 

Skinner have? 

MAJOR KING: None. 
14

STATE: How many felony convictions did Aaron Skinner 

have? 

MAJOR KING: None. 

STATE: How many battery convictions did Aaron Skinner 

have? 

MAJOR KING: None. 

STATE: How many simple assault convictions did Aaron 

Skinner have? 

MAJOR KING: None. 

The trial court again denied the motion, explaining that the 

prosecutor’s questioning of Major King was in rebuttal to defense 

counsel referring to Skinner as a “thief,” which he had done ten 

times during opening statements,5 and that Appellant was entitled 

to show Skinner’s character only by reputation or opinion evidence. 

Appellant argues that the trial court abused its discretion in 

preventing him from cross-examining Major King about Skinner’s 

 5 Defense counsel also referred to Skinner as “violent” nine times. For 

example, defense counsel stated that the jury would hear evidence that 

Skinner, “[who was a] thief[,] who was high, who was violent, who had been 

told to leave twice, and who had just heard three warning shots into a ditch 

kept coming at [Appellant].”
15

arrest pursuant to OCGA § 24-4-405 (c) (“Rule 405 (c)”). Rule 405 

(c) provides an exception to the rule that character evidence 

generally must be introduced through reputation or opinion 

testimony, see OCGA § 24-4-405 (a), allowing a party to inquire “into 

relevant specific instances of conduct” on cross-examination of a 

character witness in order to discredit the witness. See Leanos v. 

State, 303 Ga. 666, 672 (2) (c) (iii) (814 SE2d 332) (2018) (explaining 

that Rule 405 (c) allows a party to cross-examine a character witness 

about specific instances of conduct “in an attempt to undermine the 

witness’s credibility”). See also United States v. Seymour, 468 F3d 

378, 387 (II) (C) (6th Cir. 2006) (explaining that, under Federal Rule 

of Evidence 405, “inquiry into relevant specific instances of conduct 

on cross-examination is allowed only where it goes to the accuracy 

of the character witness’s testimony”) (citation and punctuation 

omitted).6 According to Appellant, Major King’s testimony showed 

 6 “Many provisions of the new Evidence Code were borrowed from the 

Federal Rules of Evidence, and when we consider the meaning of these 

provisions, we look to decisions of the federal appellate courts construing and 

applying the Federal Rules, especially the decisions of the United States 
16

that Skinner was a “law-abiding citizen” and, thus, Appellant had 

the right on cross-examination to inquire into specific instances of 

Skinner’s conduct, such as his arrest, so that the jury heard 

“balanced” rather than “exclusively positive” evidence of Skinner’s 

criminal history.

However, even assuming that the trial court abused its 

discretion in preventing Appellant from cross-examining Major King 

about Skinner’s arrest, any error was harmless. “The test for 

determining whether a non-constitutional evidentiary error was 

harmless is whether it is highly probable that the error did not 

contribute to the verdict.” Talley v. State, 314 Ga. 153, 160-161 (2) 

(875 SE2d 789) (2022). When reviewing an evidentiary error for 

harmlessness, “we review the record de novo and weigh the evidence 

as we would expect reasonable jurors to have done.” Id. at 160-161 

(2) (citation and punctuation omitted).

Here, even assuming the jury heard “exclusively positive” 

 

Supreme Court and the Eleventh Circuit.” Olds v. State, 299 Ga. 65, 69 (2) 

(786 SE2d 633) (2016).
17

evidence about Skinner’s criminal record, it is highly probable that 

any error in preventing Appellant from cross-examining Major King 

about Skinner’s arrest did not contribute to the verdict because the 

evidence against Appellant’s self-defense claim was strong. The jury 

heard testimony from the State’s ballistics expert that Skinner was 

on the opposite side of Appellant’s three-foot, barbed-wire fence 

when he was shot and that Skinner had never entered Appellant’s 

property. Moreover, the jury heard Appellant’s own assertions that 

he began firing at Skinner before Skinner appeared to raise his hand 

and point something at Appellant and that he was unsure whether 

Skinner had a gun that night. Further, the jury heard testimony 

from Driggers, who had encountered Skinner right before the 

shooting, that Skinner was clearly under the influence but not 

otherwise threatening. See Jackson v. State, 306 Ga. 69, 80 (2) (c) 

(829 SE2d 142) (2019) (concluding that evidentiary error was 

harmless “in light of the array of other strong evidence 

demonstrating Appellant’s guilt”). 

3. Appellant next claims that the trial court violated his right 
18

to due process by denying his motion to permit a ballistics expert 

retained after trial to access certain physical evidence for purposes 

of developing an ineffective-assistance-of-counsel claim in his 

motion for new trial. Appellant argues that the trial court’s denial 

of access hindered his right to appeal and deprived him of his right 

to due process of law. We are unpersuaded. 

After trial, Appellant retained a ballistics expert in an effort to 

determine whether trial counsel was ineffective for failing to present 

such an expert at trial. Appellant then moved the court to permit 

the ballistics expert to access the AK 7.62 x 39 firearm seized from 

Appellant at the time of his arrest, the magazines and cartridge 

cases obtained at the scene, and the bullets recovered at the scene 

and from Skinner’s body. 

The trial court held a status hearing on the motion, after which 

Appellant provided an affidavit from his expert, as well as a letter 

in which he claimed that an inspection and examination of the 

requested evidence could determine whether Skinner was retreating 

from or approaching Appellant’s property when he was shot. 
19

According to Appellant, if an examination revealed that the bullet 

that hit Skinner had ricocheted off the ditch, rather than the road, 

it would discredit the State’s argument that Appellant was not 

justified in shooting Skinner in self-defense because Skinner was 

retreating from Appellant’s property. The trial court summarily 

denied Appellant’s motion to access the evidentiary materials and 

proceeded with the hearing on the motion for new trial. At the 

hearing, Appellant renewed his earlier motion, which the trial court 

again denied. 

To establish an ineffective-assistance-of-counsel claim, a 

defendant must show “a reasonable probability that, but for his 

lawyer’s unprofessional errors, the result of the proceeding would 

have been different.” Mattox v. State, 308 Ga. 302, 304 (2) (840 SE2d 

373) (2020). Accordingly, a trial court does not abuse its discretion 

in denying a motion to allow an expert retained post-trial to examine 

and test the physical evidence admitted at trial for purposes of 

developing an ineffective-assistance-of-counsel claim absent a 

showing that “favorable testing results” would reveal “that the 
20

outcome of trial would have been different had trial counsel pursued 

such testing.” Battles v. State, 290 Ga. 226, 230-231 (3) (719 SE2d 

423) (2011) (concluding that “the trial court properly denied 

appellant’s request to re-test the scientific evidence” because 

appellant failed to demonstrate “how any favorable testing results 

may have affected the result at trial”). 

Here, Appellant has failed to make the required showing. 

Appellant’s hypothesis that an expert may be able to investigate the 

evidence and determine that the fatal shot ricocheted off the ditch, 

rather than the road, would be contrary to Appellant’s own 

statements that, after he fired toward Skinner, he “saw sparks come 

off [the] pavement,” “like [the bullet] hit the road,” and heard 

Skinner “holler.” See Humphrey v. Nance, 293 Ga. 189, 222 (3) (c) 

(ii) (744 SE2d 706) (2013) (trial counsel’s failure to introduce an 

expert witness who would testify that the defendant had no 

knowledge of firing the gun did not prejudice the defendant where 

“there [was] no reasonable probability that the jury would have 

found persuasive his testimony,” given the defendant’s own 
21

statements to law enforcement officers acknowledging that he fired 

the gun). Moreover, the evidence presented, which included a video 

of Skinner lying in the road and a presentation of the bullet defects 

found in the road, was consistent with the testimony of the State’s 

ballistics expert that the shot that killed Skinner “absolutely” 

ricocheted first off the road. See Robinson v. State, 277 Ga. 75, 77 

(2) (586 SE2d 313) (2003) (concluding that the defendant could not 

show a reasonable likelihood that, but for his trial counsel’s failure 

to retain an expert, the outcome of his trial would have been 

different, given that the evidence presented at trial was consistent 

with the testimony of the State’s medical examiner). Further, 

Appellant has failed to demonstrate that, even if he presented 

evidence that the fatal shot had ricocheted off the ditch rather than 

the road, there is a reasonable probability that the outcome of his 

trial would have been different. The jury was authorized to reject 

Appellant’s claim that he shot Skinner in self-defense, given that 

Appellant was shooting at Skinner from the opposite side of his 

fenced-in yard, that Skinner never entered his property, and that he 
22

was unsure whether Skinner had a gun that night. See Davis v. 

State, 312 Ga. 870, 873 (1) (855 SE2d 390) (2021) (jury authorized to 

reject self-defense claim in part because the defendant “admitted 

that he did not see [the victim] pull a gun during the incident”). 

Accordingly, Appellant’s claim fails.7

4. Appellant also argues that he received constitutionally 

ineffective assistance of counsel because defense counsel failed to 

object to the State’s questioning of Major King on redirect 

examination about Skinner’s lack of criminal convictions. According 

to Appellant, the redirect examination was improper because Major 

King had not testified on cross-examination about Skinner’s record. 

To succeed on a claim of ineffective assistance of counsel, a 

defendant must show both “that his counsel’s performance was 

professionally deficient and that he suffered prejudice as a result.” 

 7 Appellant also cites Sheard v. State, 300 Ga. 117 (793 SE2d 386) (2016), 

for the proposition that the denial of access to physical trial evidence violated 

his due process rights. Appellant’s reliance on that case is misplaced. In 

Sheard, we held that a defendant is entitled to have a trial transcript that 

allows for “adequate appellate review of the trial below” id. at 120 (2), not that 

a defendant is entitled to have trial exhibits made available for inspection posttrial.
23

Washington v. State, 313 Ga. 771, 773 (3) (873 SE2d 132) (2022) 

(citing Strickland v. Washington, 466 U.S. 668 (104 SCt 2052, 80 

LE2d 674) (1984)). To prevail on the deficiency prong, the defendant 

“must demonstrate that the lawyer performed his duties in an 

objectively unreasonable way, considering all the circumstances in 

light of the prevailing professional norms.” Davis v. State, 299 Ga. 

180, 182-183 (2) (787 SE2d 221) (2016). “To prove prejudice, [the 

defendant] must demonstrate that there is a reasonable probability 

that, but for counsel’s deficiency, the result of the trial would have 

been different.” Washington, 313 Ga. at 773 (3). “Failure to satisfy 

either prong of the Strickland test is sufficient to defeat a claim of 

ineffective assistance, and it is not incumbent upon this Court to 

examine the other prong.” Smith v. State, 296 Ga. 731, 733 (2) (770 

SE2d 610) (2015) (citation and punctuation omitted). 

Here, even assuming deficient performance, Appellant has not 

shown that Major King’s testimony about Skinner’s lack of criminal 

convictions prejudiced his defense. As we explained in Division 2,

the evidence against Appellant’s self-defense claim was strong, 
24

irrespective of whether the jury heard “exclusively positive” 

evidence about Skinner’s criminal history. The jury heard evidence 

that Skinner was on the opposite side of Appellant’s barbed-wire 

fence when he was shot and never entered his property and heard 

Appellant’s interview statements that he was unsure whether 

Skinner had a gun that night and that Appellant fired toward 

Skinner before Skinner raised his hand and pointed in Appellant’s 

direction. Given that the evidence against Appellant was strong,

Appellant has not shown a reasonable probability that, but for 

counsel’s alleged deficiency, the result of the trial would have been 

different. See Bell v. State, 294 Ga. 443, 446 (2) (754 SE2d 327) 

(2014) (concluding that any deficiency in trial counsel’s failure to 

object to the prosecutor’s questioning of a witness did not result in 

prejudice “[g]iven the substantial evidence of [the defendant’s] 

guilt”). Accordingly, this claim fails. 

5. Appellant lastly contends that the cumulative effect of the 

trial court’s assumed error in preventing Appellant from crossexamining Major King about Skinner’s arrest and trial counsel’s 
25

assumed deficiency in failing to object to the State’s redirect 

examination of Major King about Skinner’s lack of criminal 

convictions denied him a fair trial.8 We disagree.

To establish cumulative error, a defendant must demonstrate 

that “at least two errors were committed in the course of the trial” 

and “considered together along with the entire record, the multiple 

errors so infected the jury’s deliberation that they denied the 

petitioner a fundamentally fair trial.” State v. Lane, 308 Ga. 10, 21 

(4) (838 SE2d 808) (2020) (citation and punctuation omitted). When 

considering the “cumulative effect of presumed errors by trial 

counsel and the trial court,” this Court “consider[s] collectively the 

prejudicial effect, if any, of trial court errors, along with the 

prejudice caused by any deficient performance of counsel.” Patterson 

v. State, 314 Ga. 167, 181 (5) (875 SE2d 771) (2022) (citation and 

punctuation omitted). 

 8 Appellant does not argue that the trial court’s alleged error in denying

his expert access to certain physical evidence contributed to cumulative 

prejudice. However, this makes no difference in the cumulative-error analysis 

because we concluded that no error occurred. See Division 3, supra. 
26

Appellant’s claim fails. As noted above, even assuming the jury 

heard “exclusively positive” evidence of Skinner’s criminal history, 

the trial evidence rebutting Appellant’s self-defense claim was 

strong, particularly in light of Appellant’s own statements that he 

fired at Skinner before Skinner raised his hand, that he did not 

know if Skinner had a gun that night, and that Skinner never 

entered his property. Accordingly, Appellant has not demonstrated 

that the prejudicial effect of the assumed trial-court error and 

assumed deficient performance denied him a fundamentally fair 

trial. See Huff v. State, 315 Ga. 558, 568 (6) (883 SE2d 773) (2023) 

(“Appellant’s [cumulative-error] claim fails because Appellant has 

not demonstrated that the prejudicial effect of the assumed trialcourt errors and ineffective assistance denied him a fundamentally 

fair trial, given the strong evidence against him.”). 

Judgment affirmed. All the Justices concur.