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Clark v. State

2025-06-10

Summary

Holding. The judgment of the trial court is affirmed.

Dereckson Clark was convicted by jury of malice murder and related crimes in the shooting death of Alton Cotton during an outdoor dispute in 2020. Clark testified that the gun discharged accidentally during a self-defense encounter, but eyewitness evidence showed he retrieved the weapon from his car, pointed it at Cotton's unarmed head from close range, and shot Cotton after a verbal argument. The Georgia Supreme Court addressed preliminary jurisdictional questions concerning Clark's pro se notice of appeal filed after his counsel failed to appeal, then evaluated four substantive contentions on appeal: whether the trial court improperly instructed the jury about grand jury procedures; whether excluding Clark's prior testimony from the immunity hearing constituted reversible error; whether the trial judge abused discretion regarding a juror with medical needs who briefly left the courtroom; and whether trial counsel provided ineffective assistance by not moving to replace that juror.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Pro se notice of appeal validity when filed by counseled defendant
  • Jury instruction on grand jury indictment process and potential prejudice
  • Harmless error in excluding prior testimony as allegedly prior consistent statement
  • Ineffective assistance of counsel claim based on juror management strategy

Procedural posture

Clark appealed his conviction after the trial court denied his motion for new trial, raising claims of trial court error and ineffective assistance of counsel.

Authorities cited

Opinion

majority opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.

In the Supreme Court of Georgia

Decided: June 10, 2025

S25A0111. CLARK v. THE STATE.

BETHEL, Justice.

A jury found Dereckson Clark guilty of malice murder and

other crimes in connection with the shooting death of Alton Cotton.1

On appeal, Clark argues that the trial court erred in two respects

and that trial counsel rendered constitutionally ineffective

1 The crimes occurred on February 22, 2020. In November 2020, a Peach

County grand jury indicted Clark for malice murder, felony murder,

aggravated assault, and possession of a firearm during the commission of a

felony. At a June 2021 jury trial, Clark was found guilty of all counts. The trial court sentenced Clark to serve life in prison with the possibility of parole for

malice murder and a consecutive term of five years for possession of a firearm

during the commission of a felony. The remaining counts merged or were

vacated by operation of law. Clark timely filed a motion for new trial, which he

amended through new counsel. Following a hearing, the trial court denied

Clark’s motion, as amended, on February 1, 2023. On February 28, 2023,

Clark, while represented by counsel, timely filed a pro se notice of appeal.

following further proceedings in the trial court, which we detail in Division 1

below, current appellate counsel filed a notice of substitution of counsel on May

16, 2024, and the record was transmitted to this Court in August 2024. The

case was docketed to this Court’s term beginning in December 2024 and

submitted for a decision on the briefs.

assistance. For the reasons that follow, we affirm.

The evidence at trial showed that, on the afternoon of the

crimes, Clark and Cotton became involved in a verbal altercation.

The altercation took place outdoors and was observed by numerous

witnesses. Several onlookers encouraged Clark to walk away from

the dispute and go about his business. Instead, Clark returned to his

car, retrieved a revolver, and walked back toward Cotton. When

Clark reached Cotton, he told Cotton, “I’m tired of you f**king with

me,” then aimed the revolver at Cotton’s head and shot him. Clark

then left the scene. Cotton died as a result of the gunshot wound to

his head, and the autopsy revealed that the gun was fired from

within one or two inches of his head. Responding officers did not

locate a weapon of any kind near Cotton, and none of the bystanders

reported that Cotton had a weapon. Testimony at trial established

that Cotton did not threaten Clark, nor did Cotton have anything in

his hands before Clark shot him.

Clark filed a motion for pretrial immunity based on selfdefense, which the trial court denied after an evidentiary hearing.

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Clark testified in his own defense at trial, claiming that, after Cotton

threw a rock at him, he armed himself in self-defense and that the

gun accidentally fired. At trial, Clark acknowledged his prior

testimony at the pretrial immunity hearing that he thought, if he

showed Cotton his gun, “I knew he would leave me alone. I thought

maybe he would leave me alone permanently, you know, just leave

me alone. Just cut loose, period. Get – just get over it.” Clark also

admitted that he had testified that Cotton “wasn’t threatening me,

but he was just cursing at me.”

1. Before reaching Clark’s enumerations of error, we address

an issue with the notice of appeal in this case. See Kelly v. State, 311

Ga. 827, 828 (860 SE2d 740) (2021) (“It is the duty of this Court to

inquire into its jurisdiction in any case in which there may be a

doubt about the existence of such jurisdiction. The proper and timely

filing of the notice of appeal is an absolute requirement to confer

jurisdiction upon the appellate court.” (cleaned up)). As noted in

footnote 1, Clark was represented by counsel at the motion-for-newtrial stage. For reasons not apparent from the record, counsel

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neglected to file a notice of appeal following entry of the order

denying the motion for new trial on February 1, 2023, though there

is no indication that counsel formally withdrew from his

representation of Clark. On February 28, 2023, Clark filed in the

trial court a timely pro se notice of appeal in which he also asked

that appellate counsel be appointed to represent him. Following a

hearing, the trial court entered an order finding that Clark “was

diligent in acting on his own behalf to file his timely Notice of Appeal

when his counsel failed to do so” and that his pro se notice of appeal

should be recognized “as a cognizant filing for the limited purpose of

preserving [Clark’s] right to pursue” an appeal. The court further

found that Clark had neither waived his right to counsel nor

asserted his right to self-representation.

When a defendant makes a timely and otherwise procedurally

proper pro se filing while still formally represented by counsel, a

question arises whether the court should exercise its discretion to

recognize the validity of that filing. See Johnson v. State, 315 Ga.

876, 890 (4) (885 SE2d 725) (2023) (holding that a pro se filing by a

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counseled defendant is not per se a legal nullity and that “a court

has the discretion to recognize a timely and otherwise procedurally

proper pro se filing made by a defendant who is still formally

represented by counsel”). “[T]he decision whether to recognize a pro

se notice of appeal remains one for appellate courts to make.” Id. at

877, 891 (4) n.15 (instructing that “when a court chooses to recognize

such a filing . . . it should make that exercise of discretion clear on

the record”). And we are aided in that task here by the trial court’s

careful attention to preparing a record on this issue. On this record

and with the benefit of the trial court’s findings, we exercise our

discretion to recognize Clark’s timely notice of appeal and proceed

to address the merits of his appeal. See id. at 890-891 (4) (observing

that exercising discretion to recognize “a pro se filing [that] would

preserve a right of appeal that would otherwise be lost through no

fault of the defendant . . . seem[s] to us squarely in the furtherance

of justice” (citation and punctuation omitted)).

2. Turning to his first claim of error, Clark asserts that the trial

court erred by instructing the jury about the grand jury process.

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Specifically, as part of the preliminary jury instructions, the trial

court noted that “[t]he State cannot bring a person accused of a

felony to trial unless the grand jury has first indicted that person.

Grand [j]urors do not try criminal cases. They ordinarily only hear

from witnesses for the State.” Clark did not object to this instruction

at trial, so this claim may be reviewed only for plain error. See State

v. Kelly, 290 Ga. 29, 32 (1) (718 SE2d 232) (2011); OCGA § 17-8-57

(b). To show plain error, Clark “must demonstrate that the

instructional error was not affirmatively waived, was obvious

beyond reasonable dispute, likely affected the outcome of the

proceedings, and seriously affected the fairness, integrity, or public

reputation of judicial proceedings.” Hill v. State, 310 Ga. 180, 194

(11) (a) (850 SE2d 110) (2020) (citation and punctuation omitted).

“To constitute plain error, an error in a jury instruction must have

been obvious, among other things.” Harris v. State, 313 Ga. 872, 879

(3) (874 SE2d 73) (2022).

In Clark’s estimation, the challenged instruction was

erroneous because the jury might have misunderstood it to mean

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that a different jury had already heard the evidence against Clark

and found him guilty of the charged crimes, and he asserts that the

trial court should have instructed the trial jury about the lower

standard of proof required for indictment. But Clark points to no

precedent holding that it is error to instruct the trial jury about the

grand jury process or detailing the level of specificity necessary for

such an instruction. Indeed, the only two cases Clark cites in support

of this claim held that no error existed where the trial court

instructed the trial jury about the grand jury process and, as the

court did in this case,2 also instructed the jury about the

2 The challenged instruction came in the context of the following

instructions:

[W]e sort of take things for granted that people understand

legal proceedings and they don’t necessarily. So I’d like to give you

just a little background information.

A crime is a violation of a statute of this State in which there

shall be a union of — or joint operation of an act and intention.

That is, a crime is committed when a person violates a statute of

this State, which is to say a law of this State, by acting as

prohibited, while at the same time he has a criminal intention, and

no other defense excuses the conduct. A person will not be

presumed to act with criminal intention. However, the jury may

find such intention upon consideration of the words, conduct,

demeanor, motive, and all other circumstances connected with the

act for which the accused is prosecuted.

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presumption of innocence and the State’s burden of proof. See

Shadron v. State, 275 Ga. 767, 769-770 (3) (573 SE2d 73) (2002) (no

reversible error where instruction about grand jury process did not

mislead the jury about “the State’s burden of proof at any stage of

the proceeding and . . . did not diminish the presumption of

innocence” when viewed in context of entire jury charge); Bostic v.

State, 184 Ga. App. 509, 510 (3) (361 SE2d 872) (1987) (no reversible

error where trial court’s instruction, viewed as a whole, “was a

correct statement of the function of the grand jury, was not

misleading, and did not shift the burden of proof”). And because “[a]n

error cannot be plain where there is no controlling authority on

The State cannot bring a person accused of a felony to trial

unless the grand jury has first indicted that person. Grand Jurors

do not try criminal cases. They ordinarily only hear from witnesses

for the State.

When a criminal case is tried, the Defendant has pled not

guilty to the Indictment. This plea of not guilty denies every

essential allegation of the Indictment and forms the issue or

question that you, as a trial jury, will decide. The Indictment and

the plea of not guilty to it are not evidence and you should not

consider them as evidence. Every person is presumed innocent

until proved guilty. No person shall be convicted of a crime unless

each element of the crime is proved beyond a reasonable doubt.

The State has the burden to prove each essential element of each

crime charged beyond a reasonable doubt.

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point,” Clark’s claim fails at the second step of plain-error review.

Hill, 310 Ga. at 194 (11) (a) (citation and punctuation omitted). See

also Payne v. State, 314 Ga. 322, 325 (1) (877 SE2d 202) (2022) (“[We

do] not have to analyze all elements of the plain-error test where an

appellant fails to establish one of them.”).

3. Clark next argues that the trial court erred by sustaining

the State’s hearsay objection to Clark’s reading into evidence his

testimony from the pretrial immunity hearing. Specifically, the

prosecutor cross-examined Clark about certain aspects of his

testimony at the immunity hearing and read portions of that prior

testimony into the record. On redirect, Clark’s counsel asked Clark

to read into the record additional portions of his prior testimony. The

State objected on hearsay grounds, and the trial court sustained the

objection, indicating that Clark could not simply read his prior

testimony into the record. On appeal, Clark asserts that this was

error because, he says, the prior testimony was admissible as a prior

consistent statement. The State argues that Clark did not preserve

this argument for ordinary appellate review because he made no

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express argument at trial that the prior testimony was admissible

as a prior consistent statement.3 But even assuming that Clark did

preserve this claim and that the trial court erred, we conclude that

any such error was harmless and does not warrant reversal.

3 In determining the appropriate standard of review for a claim of

evidentiary error, we have explained that “[w]here an appellant challenges the

admission of evidence, we are concerned with the sufficiency of the appellant’s

objection,” but “where the appellant challenges the exclusion of evidence, we

are concerned with the sufficiency of the showing that the appellant, as

proponent of the evidence, made at trial.” Williams v. State, 302 Ga. 147, 151

(2) (805 SE2d 873) (2017). “[T]o preserve an objection to the exclusion of

evidence, the proponent must either make an offer of proof or otherwise ensure

that the reason for offering the evidence in question [is] apparent to the trial

court.” McGarity v. State, 311 Ga. 158, 162 (2) (856 SE2d 241) (2021) (citation

and punctuation omitted; emphasis in original). And where a defendant

advances on appeal a different theory of admissibility than he argued at trial,

the claim is not preserved for ordinary appellate review. See Smith v. State,

309 Ga. 240, 250 (3) (845 SE2d 598) (2020) (where trial court excluded

testimony as hearsay, claim that testimony was admissible as a prior

consistent statement under OCGA §§ 24-6-613 (c) and 24-8-801 (d) (1) (A) was

not preserved for ordinary appellate review because appellant argued in trial

court only that testimony was admissible under OCGA §§ 24-8-803 (4) and 24-7-703). See also Williams, 302 Ga. at 151 (2); Lupoe v. State, 300 Ga. 233, 247

(11) (794 SE2d 67) (2016).

Here, the State is correct that the record does not reflect that Clark

expressly argued at trial that his testimony from the immunity hearing was

admissible as a prior consistent statement. Rather, the extent of Clark’s

response to the State’s hearsay objection was a comment that the prosecutor

“used [the prior testimony] as a prior inconsistent statement, with only reading

half of Mr. Clark’s response.” It is not readily apparent that this argument was

sufficient to apprise the trial court that Clark sought to admit the testimony

as a prior consistent statement and thereby preserve this claim for ordinary

appellate review. And we express no opinion on that question. We do not

resolve that issue because Clark’s argument fails even under ordinary review.

10

“We review a trial court’s evidentiary rulings under an abuse

of discretion standard of review. And even where an abuse of

discretion is shown, there are no grounds for reversal if the error did

not affect a substantial right, and thus harm, the defendant.”

Neuman v. State, 311 Ga. 83, 91 (4) (a) (i) (856 SE2d 289) (2021)

(citation and punctuation omitted). Here, the record reflects that,

though Clark was prohibited from reading his prior testimony from

the transcript of the pretrial hearing, his trial counsel elicited the

same testimony from Clark without use of the transcript —

specifically, testimony that Clark retrieved his gun from his car

after Cotton threatened him with a rock — as well as testimony that

Clark previously testified to that effect at the pretrial hearing. As

such, Clark’s reading for the jury his prior testimony would have

been “essentially cumulative, and it is highly unlikely that such

additional evidence would have had any effect on the verdict.” Cook

v. State, 312 Ga. 299, 302 (2) (862 SE2d 510) (2021) (any error in

excluding testimony about acts of violence committed by victim

against third parties was harmless because other evidence

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established that victim had reputation for violence, was known to

carry a gun, and previously assaulted appellant and, thus, excluded

testimony was “essentially cumulative”); Walker v. State, 306 Ga.

44, 47 (2) (829 SE2d 121) (2019) (any error in excluding testimony

that appellant said victim tried to kill him was cumulative and

harmless because appellant testified that he acted in self-defense

and responding officer testified that appellant claimed victim had

shot him). Moreover, the evidence of Clark’s guilt was

overwhelming, and eyewitness testimony established that Clark

shot the unarmed victim after a verbal dispute and then fled the

scene, not that he acted in self-defense. See id. (where evidence of

guilt is “overwhelming,” erroneous exclusion of evidence is

harmless). Accordingly, any error by the trial court in limiting

Clark’s testimony was harmless, and this claim fails.

4. Finally, Clark asserts that trial counsel rendered

constitutionally ineffective assistance by failing to request an

inquiry into whether a juror should have been replaced with an

alternate. Specifically, he points to a juror who, according to the trial

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court, “had an issue with urinary urgency” and twice left the

courtroom during the presentation of evidence to relieve himself,

with the trial court pausing the presentation of evidence in the

juror’s absence on both occasions. To prevail on a claim of ineffective

assistance, an appellant bears the burden of showing both that trial

counsel’s performance was professionally deficient and that he was

prejudiced as a result of that deficient performance. See Strickland

v. Washington, 466 U. S. 668, 695 (III) (104 SCt 2052, 80 LE2d 674)

(1984). To show deficient performance, an appellant “must overcome

the strong presumption that counsel’s performance fell within a

wide range of reasonable professional conduct and that counsel’s

decisions were made in the exercise of reasonable professional

judgment.” Lockhart v. State, 298 Ga. 384, 385 (2) (782 SE2d 245)

(2016) (citation and punctuation omitted). And to show prejudice, an

appellant “must show a reasonable probability that, but for counsel’s

unprofessional errors, the result of the proceeding would have been

different.” Simpson v. State, 298 Ga. 314, 318 (4) (781 SE2d 762)

(2016) (citation and punctuation omitted). Clark has not met this

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burden.

It is well settled that “juror selection is a matter of trial tactics

and strategy,” and “a decision implicating trial tactics and strategy

can serve as the basis for an ineffectiveness claim only if it is so

patently unreasonable that no competent attorney would have made

such a decision.” Capps v. State, 300 Ga. 6, 12-13 (2) (e) (792 SE2d

665) (2016) (citation omitted). Here, Clark rests his claim of

ineffectiveness on speculation that other jurors may have been

distracted by the interruption when the juror at issue exited the

courtroom and that the juror may have needed an opportunity to

rehear missed testimony, which, he says, could have served as

reasons for the juror’s removal such that trial counsel should have

inquired into the issue. But at the motion for new trial hearing, trial

counsel testified that she did not view the juror’s “bladder control

issues” and need for “more frequent breaks” “as a reason to ask for

an alternate to be sat.” She explained, “[the juror] had a medical

condition and we were accommodating that” by pausing the

presentation of evidence when the juror needed a break, as the trial

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transcript reflects. Counsel insisted that she “didn’t feel that it was

necessary” to seat an alternate juror and rejected the notion that the

juror’s bathroom breaks were disruptive to the other jurors. Counsel

also affirmed that she wanted this particular juror on the jury.

In the order denying Clark’s motion for new trial, the trial

court expressly credited counsel’s testimony — a determination that

Clark does not challenge as clearly erroneous. See Lockhart, 298 Ga.

at 385 (2) (“We accept the trial court’s factual findings and

credibility determinations unless clearly erroneous, but we

independently apply the legal principles to the facts.” (citation and

punctuation omitted)). Thus, the record shows that trial counsel

considered and rejected both reasons advanced by Clark as a basis

for the juror’s removal, and Clark makes no effort to demonstrate

that counsel’s strategic decision not to seek the juror’s removal was

otherwise unreasonable. See Parker v. State, 305 Ga. 136, 142-143

(4) (b) (823 SE2d 313) (2019) (rejecting claim of ineffective assistance

of counsel based on counsel’s failure to strike a prospective juror

where counsel articulated a strategic reason to include the

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prospective juror on the jury and appellant failed to show that

counsel’s strategy was unreasonable). As such, Clark has failed to

meet his burden of showing that no reasonable counsel would have

made that strategic decision, and his ineffective assistance claim

fails. See Bradley v. State, 318 Ga. 142, 144 (2) (897 SE2d 428) (2024)

(“The failure to demonstrate either deficient performance or

resulting prejudice is fatal to a claim of ineffective assistance of

counsel and obviates the need even to consider the other.”).

Judgment affirmed. Peterson, CJ, Warren, PJ, and Ellington,

McMillian, LaGrua, Colvin, and Pinson, JJ, concur.

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