I. Introduction

In Dixon v. State, S26A0052 (Ga. Dec. 9, 2025), the Supreme Court of Georgia affirmed Brandi Dixon’s conviction for felony murder predicated on aggravated assault arising from the fatal stabbing of Ebony Smith during a confrontation over a shared romantic partner, George “Little Man” Duehart.

The Court addressed four core issues:

1. Whether the evidence was constitutionally sufficient to sustain a felony murder conviction and to defeat Dixon’s motion for a directed verdict, given her claim of self‑defense.
2. Whether trial counsel rendered constitutionally ineffective assistance by advising Dixon not to testify.
3. Whether the trial court abused its discretion in allowing a limited redirect question to Smith’s sister, and whether any error was harmless.
4. Whether the State violated its expert-disclosure obligations under OCGA § 17‑16‑4(a)(4) by eliciting general forensic testimony from the medical examiner without a written report, and whether the trial court erred in refusing to strike that testimony.

Although the Court ultimately affirmed without announcing a sweeping new doctrine, the opinion meaningfully clarifies several recurring points in Georgia criminal practice:

• How juries may reject a self-defense claim by finding the defendant the “initial aggressor” even where the victim fired a weapon.
• How appellate courts treat ineffective-assistance claims premised on counsel’s advice not to testify, especially where the record is undeveloped.
• How harmless-error analysis operates for minor evidentiary rulings.
• And most significantly, how OCGA § 17‑16‑4(a)(4)’s expert-report disclosure requirement does not extend to an expert’s general explanatory testimony not based on case-specific tests or examinations—building on Green v. State.

II. Summary of the Opinion

A. Factual Overview

The evidence, viewed in the light most favorable to the verdict, showed:

• Both Dixon and Smith were in romantic relationships with Duehart. The State’s evidence suggested Dixon suspected the overlap and had earlier, somewhat tense encounters with Smith or her family (at a ballfield; at Smith’s home asking for “Little Man”).
• At a 2018 party hosted by Duehart, a witness saw Dixon at the top of a hill near the house, “twirling” a knife and loudly and aggressively asking where “Little Man” was, threatening to “kill … a b**ch tonight.”
• Later, as Smith and her friend Ashley Oliver returned from a store, Dixon confronted Smith near her car and asked if she was there for “Little Man.” Smith responded, “That’s my man.” Dixon got “in [Smith’s] face” aggressively while two men held Oliver back.
• Smith then reached into her car, took a pistol from the glove compartment, loaded it, and fired into the air. Accounts differed as to whether Dixon had already brandished a knife when Smith fired.
• Oliver told officers on scene that Dixon had pulled a knife on Smith and that Smith shot at Dixon in self-defense, whereupon Dixon stabbed Smith in the chest with a large kitchen knife. Smith died from a four‑inch deep chest stab wound.
• Dixon suffered a minor forehead injury described as a “nick” or “minor cut.” An investigator opined that it did not appear to be a gunshot wound.

Dixon’s trial theory was self-defense. She did not testify at trial.

B. Holdings

1. Sufficiency of the evidence / directed verdict: Applying Jackson v. Virginia and Rooks v. State, the Court held the evidence allowed a rational jury to:
   • Reject Dixon’s self-defense claim,
   • Find her the initial aggressor under OCGA § 16‑3‑21(b)(3), and
   • Find her guilty beyond a reasonable doubt of felony murder based on aggravated assault.
   Denial of the directed verdict motion was therefore proper.
2. Ineffective assistance (advice not to testify): Under Strickland v. Washington and Georgia precedent (Woods, Morgan, Newman), Dixon failed to prove deficient performance. She presented no evidence of counsel’s reasoning or what her testimony would have been. The Court presumed counsel’s advice not to testify was a reasonable strategic decision.
3. Redirect question to Smith’s sister: Assuming arguendo a possible abuse of discretion, any error in allowing the sister to testify that she—not Smith— would have been the one to respond to aggression was harmless. Her answer was brief and cumulative of unchallenged evidence that Smith was not aggressive or violent.
4. Expert-disclosure challenge under OCGA § 17‑16‑4(a)(4): The medical examiner had not provided a report on whether Dixon’s forehead injury was a gunshot wound. The trial court excluded that opinion. But it allowed the examiner to testify generally about the typical appearance of stab wounds, gunshot wounds, and graze wounds. The Supreme Court held:
   • This general explanatory testimony did not constitute a “report of any physical or mental examinations and of scientific tests or experiments” under OCGA § 17‑16‑4(a)(4).
   • It was based on the examiner’s general experience, not a case‑specific test or examination, so no written report or disclosure was statutorily required.
   • Accordingly, the trial court did not abuse its discretion in declining to strike that testimony.

The Supreme Court unanimously affirmed Dixon’s conviction and the denial of her motion for new trial.

III. Detailed Analysis

A. Factual and Procedural Context

The prosecution arose from a highly emotionally charged confrontation: two women in overlapping relationships with the same man encounter each other at a party; one appears armed and verbally threatening beforehand; a firearm is discharged; a fatal stabbing follows almost immediately.

Procedurally:

• Dixon was indicted in Bibb County for malice murder and felony murder based on aggravated assault.
• In March 2022, a jury acquitted her of malice murder but convicted her of felony murder, and she was sentenced to life imprisonment.
• She filed a timely motion for new trial (later amended). The trial court denied it in June 2025.
• Dixon appealed, raising sufficiency, ineffective assistance, and evidentiary issues.

B. Sufficiency of the Evidence and Self‑Defense

1. The Jackson v. Virginia framework

The Court reiterates that the Jackson v. Virginia, 443 U.S. 307 (1979), standard governs:

• On direct appeal, courts must view the evidence “in the light most favorable to the verdict.”
• The question is not whether the appellate court believes the evidence proves guilt beyond a reasonable doubt, but whether any rational trier of fact could so find.
• All issues of witness credibility, weight of evidence, and resolution of conflicts are left to the jury.

Importantly, the Court also confirms that this same standard applies to review of the denial of a motion for a directed verdict of acquittal, citing Rooks v. State, 317 Ga. 743 (2023).

2. The key conflict: who was the aggressor?

Dixon framed her sufficiency argument around self-defense: she claimed the State had not disproved justification beyond a reasonable doubt. She relied particularly on Ashley Oliver’s trial testimony that Smith fired the gun before Dixon produced a knife.

The Court’s analysis proceeds in two steps:

1. Identifying evidence that Dixon was the aggressor. The Court emphasizes:
   • Prior encounters in which Dixon approached Smith or her family (the ballfield incident, the visit to Smith’s house asking for “Little Man”), suggesting Dixon had animus or at least suspicious interest.
   • At the party, an eyewitness saw Dixon “twirling” a large kitchen knife while loudly and aggressively threatening to “kill … a b**ch tonight,” asking where “Little Man” was.
   • Later, Dixon aggressively confronted Smith at her car, got in her face, while two men restrained Oliver from intervening.
   This sequence allowed the jury to infer that Dixon initiated the final confrontation and brought a deadly weapon to it.
2. Reconciling conflicting accounts about the gunshot. Oliver’s trial testimony that Smith fired in the air before Dixon pulled a knife was not the only account. On body-cam footage at the scene (when Oliver was “very distraught”), she told investigators Dixon had pulled a knife on Smith, Smith defended herself and shot Dixon, and Dixon then stabbed Smith. The Court underscores that:
   • It is the jury’s job to choose between Oliver’s in‑court account and her earlier statement to police.
   • Appellate courts do not reweigh the credibility of those statements.

3. The legal overlay: justification and the initial aggressor rule

OCGA § 16‑3‑21(b)(3) provides that a person is not justified in using force in self‑defense if they were “the aggressor.”

Relying on Gibbs v. State, 309 Ga. 562 (2020), and Carter v. State, 310 Ga. 559 (2020), the Court reiterates:

• Questions about whether a killing was justified are for the jury.
• The jury may accept or reject any portion of the evidence supporting self-defense.
• Even where there is conflicting evidence about who drew or fired a weapon first, the jury can still find that the defendant was the initial aggressor and therefore not justified.

In Gibbs, despite conflicting testimony about who fired first, the Court upheld a felony murder conviction where the jury could find the defendant was not acting in self-defense. In Carter, the Court held that even if the jury believed the victim fired first, other evidence supported a finding that the defendant had been the initial aggressor.

4. Application to Dixon

The Court concludes the evidence was sufficient because:

• Dixon’s prior conduct toward Smith and her family, her visible brandishing of a kitchen knife, and her explicit threats at the party allowed the jury to see her as the aggressor well before Smith’s gunshot.
• The jury could discount Oliver’s trial testimony that Smith fired before Dixon produced the knife in favor of Oliver’s immediate out-of-court account indicating Dixon pulled a knife first.
• Even assuming Smith fired first, under Carter and Gibbs the jury was entitled to find Dixon was still the initial aggressor in the overall sequence of events, thereby losing the shield of justification.

Under Jackson, that is enough: a rational juror could find the elements of felony murder predicated on aggravated assault and could reject self-defense beyond a reasonable doubt. The directed verdict motion was properly denied.

C. Ineffective Assistance and the Right to Testify

1. Strickland framework

The Court applies the familiar two‑pronged test from Strickland v. Washington, 466 U.S. 668 (1984):

1. Deficient performance: Counsel’s performance must fall below an objective standard of reasonableness under prevailing professional norms.
2. Prejudice: There must be a reasonable probability that, but for counsel’s errors, the outcome of the trial would have been different.

The Court stresses the strong presumption that counsel’s conduct falls within the wide range of reasonable professional assistance, quoting Woods v. State, 322 Ga. 365 (2025) and Warren v. State, 314 Ga. 598 (2022).

2. Tactical nature of the decision to testify

Drawing on Morgan v. State, 321 Ga. 495 (2025), the Court notes:

• Whether to testify is ultimately a choice for the defendant, but it is made after consultation with counsel.
• Counsel’s advice on whether to testify is a strategic or tactical decision, not automatically suspect.
• Strategic decisions are shielded from second‑guessing unless they are “so patently unreasonable that no competent attorney would have followed such a course.”

3. The evidentiary gap in Dixon’s claim

At the motion for new trial hearing:

• Dixon testified that shortly before trial, counsel had “wanted [her] to testify,” and she was ready to do so.
• During trial, however, he advised her not to take the stand; she “wanted to tell [her] side.”
• She did not call trial counsel to explain his reasoning.
• She did not describe what her testimony would have been in any detail.

The trial record further showed that the court personally advised Dixon about her right to testify:

• The judge told her she had the right to testify and that no one could prevent her from doing so.
• The judge emphasized the decision belonged to her, not to her lawyer.
• Dixon confirmed she understood and that she “personally” did not wish to testify.

Against this backdrop, the Court cites Woods and Newman v. State, 309 Ga. 171 (2020), emphasizing that when the record is silent regarding counsel’s advice and strategy, appellate courts presume the advice was strategic and constitutionally reasonable.

4. No showing of deficient performance

The Court does not even reach the prejudice prong because Dixon failed to establish deficiency:

• Without testimony from counsel or any explanation from Dixon about the substance of her proposed testimony, there is no basis to conclude that advising her not to testify was “patently unreasonable.”
• Under Georgia law, the absence of such evidence triggers the presumption that the decision was strategic and within the wide range of professional competence.

The opinion also notes that any further ineffectiveness arguments (e.g., limited pretrial consultation, ignoring alleged exculpatory evidence) were mentioned only in passing in Dixon’s brief and unsupported by argument. Under Supreme Court Rule 22 and Byrd v. State, 321 Ga. 222 (2025), they are deemed abandoned.

D. Redirect Examination and Harmless Error

1. The challenged question

On direct, Smith’s sister testified that:

• She and Smith saw Dixon at a ballfield and noticed Dixon pointing at them.
• She took a baseball bat “in case [Dixon] came up there and tried to jump on [Smith].”

On cross, defense counsel elicited that:

• The sister had never heard Dixon threaten Smith.
• Smith carried a gun because her neighborhood was dangerous, not because she was violent.

On redirect, the State asked, referencing the bat for “protection”:

“Between the two of you, who would have been the one to respond to any kind of aggression?”

Over defense objection (scope of redirect), the trial court allowed the question. The sister answered, “Me.”

2. Harmless-error analysis

Without resolving whether this exceeded the permissible scope of redirect, the Court applies the non‑constitutional harmless-error standard from Scott v. State, 317 Ga. 799 (2023):

A non-constitutional error is harmless if it is highly probable that the error did not contribute to the verdict.

The Court finds:

• The sister’s one-word answer (“Me”) was extremely brief.
• The point it conveyed—that Smith was less likely than the sister to respond aggressively—was cumulative of other, unchallenged evidence:
  • The sister’s direct testimony that Smith was not known to be aggressive.
  • Duehart’s testimony that he had never known Smith to be aggressive or violent.

Following Scott and Monroe v. State, 315 Ga. 767 (2023), the Court holds that any error in permitting this question was harmless because it was cumulative and unlikely to have influenced the verdict.

E. Expert Disclosure Under OCGA § 17‑16‑4(a)(4)

1. The statutory requirement

OCGA § 17‑16‑4(a)(4) imposes discovery obligations on the prosecution with respect to expert witnesses. As pertinent here, the State must permit the defense to inspect and copy:

• “[T]he report of any physical or mental examinations and of scientific tests or experiments,” or
• If the report is oral or partially oral, the State must reduce all relevant and material oral portions to writing and serve them on defense counsel.

2. What was excluded, and what was allowed

At trial:

• The medical examiner was qualified as an expert and had performed Smith’s autopsy.
• The State had disclosed the autopsy report, but not any separate report concerning Dixon’s forehead injury.

When the State attempted to elicit the medical examiner’s opinion, based on her review of photographs, as to whether Dixon’s forehead injury was a gunshot wound, defense counsel objected under § 17‑16‑4(a)(4). The trial court sustained the objection and excluded that opinion testimony.

However, the State was then permitted to ask only general questions in front of the jury:

• What do stab wounds typically look like?
• What do gunshot wounds typically look like?
• What is a “graze” gunshot wound, and how does it generally appear?

The medical examiner answered in purely generic terms (e.g., stab wounds usually “linear,” gunshot wounds “round or ovoid” with marginal abrasion; graze wounds are elongated, superficial scrapes). When the State asked whether a graze wound would look different from a cut, defense objected and moved to strike. The trial court sustained the objection but declined to strike prior testimony, and the State concluded the examination.

3. The Court’s interpretation of § 17‑16‑4(a)(4)

The Supreme Court focuses on the nature of the testimony at issue:

• The challenged testimony did not describe the examiner’s case‑specific review of Dixon’s injury photos or an opinion about that wound.
• It consisted solely of the examiner’s explanation of general, textbook features of different wound types, drawn from her experience.

Citing Green v. State, 307 Ga. 171 (2019), the Court reiterates that:

An expert’s opinion that is based almost entirely upon his own observations and measurements of the available evidence, as well as application of established principles … did not constitute a “scientific test or experiment” requiring disclosure under OCGA § 17‑16‑4(a)(4).

Building on Green, the Court clarifies that:

• General explanatory testimony about the characteristics of wounds, grounded in an expert’s training and experience, is not a “report of any physical or mental examinations and of scientific tests or experiments” within the meaning of the statute.
• Accordingly, such testimony is not subject to the specific expert-report disclosure requirement of § 17‑16‑4(a)(4).

Because the State did not seek to introduce an undisclosed report or case‑specific test results through this line of questioning, the Court holds the trial court did not abuse its discretion in refusing to strike the general wound‑type testimony.

The Court expressly declines to opine on whether the trial court was correct to exclude the examiner’s case‑specific opinion about Dixon’s forehead injury, leaving that ruling undisturbed but not endorsed.

IV. Precedents Cited and Their Influence

A. Federal Benchmarks

• Jackson v. Virginia, 443 U.S. 307 (1979) – Establishes the constitutional sufficiency standard: whether any rational trier of fact could find guilt beyond a reasonable doubt, viewed in the light most favorable to the verdict.
• Strickland v. Washington, 466 U.S. 668 (1984) – Sets forth the two‑part test for ineffective assistance of counsel (deficient performance and prejudice), with a strong presumption of reasonable professional assistance.

B. Georgia Supreme Court Decisions on Sufficiency and Justification

• Rooks v. State, 317 Ga. 743 (2023) – Confirms Jackson as the standard for both sufficiency challenges and review of denied directed-verdict motions. Emphasizes appellate deference to jury determinations.
• Gibbs v. State, 309 Ga. 562 (2020) – Holds that juries decide justification, may reject self-defense despite conflicting evidence about who fired first, and reiterates that self-defense is a question for the factfinder.
• Carter v. State, 310 Ga. 559 (2020) – Affirms that even if the victim fired first, the defendant can still be found the initial aggressor and thus unjustified.

C. Georgia Ineffective-Assistance and Right-to-Testify Cases

• Woods v. State, 322 Ga. 365 (2025) – Reaffirms the strong presumption of reasonable performance and holds that without evidence of counsel’s advice regarding testifying, an IAC claim on that ground fails.
• Morgan v. State, 321 Ga. 495 (2025) – Clarifies that whether to testify is ultimately the defendant’s decision, but counsel’s advice not to testify is a strategic decision.
• Newman v. State, 309 Ga. 171 (2020) – Presumes counsel’s advice regarding testifying is strategic where the record is silent; emphasizes the need to develop a record at the motion for new trial stage.
• Warren v. State, 314 Ga. 598 (2022) – Articulates the “no reasonable lawyer” formulation of deficient performance: a defendant must show that no reasonable lawyer would have acted as trial counsel did.

D. Harmless Error and Appellate Practice

• Scott v. State, 317 Ga. 799 (2023) – Defines harmlessness for non‑constitutional error as “highly probable” that the error did not contribute to the verdict; used here to resolve the redirect issue.
• Monroe v. State, 315 Ga. 767 (2023) – Example of assuming evidentiary error but finding it harmless when the evidence is brief and cumulative.
• Byrd v. State, 321 Ga. 222 (2025) – Applies Supreme Court Rule 22 to deem arguments abandoned when not supported by developed argumentation in the brief.

E. Expert Disclosure and Scientific Evidence

• Green v. State, 307 Ga. 171 (2019) – Interprets OCGA § 17‑16‑4(a)(4), holding that an expert’s application of established mathematical and physical principles to observed evidence does not amount to a “scientific test or experiment” requiring pretrial disclosure.

Dixon relies heavily on these precedents rather than forging new doctrinal ground. Its significance lies in how it applies them to a common fact pattern—self-defense in a domestic dispute, ineffective assistance based on the decision not to testify, and forensic testimony about wounds—and further clarifies their practical operation.

V. Complex Concepts Simplified

A. Felony Murder and Aggravated Assault (Georgia)

• Felony murder: A person commits felony murder if someone dies during the commission of a felony, regardless of whether the killer specifically intended to cause death. Here, the underlying felony was aggravated assault (stabbing with a knife).
• Aggravated assault: An assault committed with a deadly weapon (such as a knife) or with intent to murder, rape, or rob. Stabbing someone in the chest with a kitchen knife qualifies.

B. Self‑Defense and the Initial Aggressor Rule

• Georgia law justifies the use of force in self-defense if a person reasonably believes it is necessary to prevent imminent unlawful force.
• However, under OCGA § 16‑3‑21(b)(3), a person is not justified if they were the “aggressor” in the encounter.
• The “initial aggressor” is the person who starts or provokes the violent confrontation. If a jury finds the defendant in that role, self-defense is unavailable.

C. Directed Verdict of Acquittal

• A motion for directed verdict asks the judge to acquit the defendant because, even taking the evidence in the light most favorable to the State, no reasonable jury could find guilt.
• Georgia courts apply the same standard as for sufficiency on appeal: the Jackson rational‑juror test.

D. Ineffective Assistance of Counsel

• To prevail, a defendant must show: (1) counsel’s performance was objectively unreasonable, and (2) this poor performance probably changed the outcome.
• Court strongly defers to counsel’s strategic decisions, especially choices like whether the defendant should testify.
• Without evidence explaining counsel’s strategy or the substance of the missing testimony, courts almost never find ineffectiveness.

E. Expert Discovery Under OCGA § 17‑16‑4(a)(4)

• The State must disclose reports of any physical or mental examinations and scientific tests or experiments.
• If such a “report” is oral, the State must reduce relevant parts to writing and provide them to the defense.
• General educational or background testimony by an expert—explaining, for example, how certain types of wounds usually look—is not a report of a test or examination and need not be disclosed as such.

F. Harmless Error (Non‑Constitutional)

• Not every trial error results in reversal. For non‑constitutional evidentiary errors, the question is whether it is “highly probable” the error did not affect the verdict.
• If the improper evidence is brief and says nothing the jury did not already hear from other, properly admitted sources, it is typically deemed harmless.

VI. Impact and Implications

A. Self‑Defense Homicide Cases

Dixon reinforces a consistent message from the Georgia Supreme Court:

• Self-defense claims are fact‑intensive and largely entrusted to juries.
• Appellate courts will not overturn verdicts merely because there is conflicting evidence about who brandished or fired a weapon first.
• When the defendant has engaged in prior antagonistic behavior or arrives armed and making threats, juries have broad latitude to label the defendant the initial aggressor and to reject justification.

Practically, this underscores the importance for defense counsel to address thoroughly any pre‑incident hostile conduct and to present a coherent, fact‑supported narrative that the defendant was reacting to an imminent threat, not instigating it.

B. Ineffective Assistance Claims Based on Advice Not to Testify

Dixon, in line with Woods, Morgan, and Newman, sends several clear signals:

• Simply asserting, after conviction, “My lawyer told me not to testify” is not enough to establish deficiency.
• Defendants must create a post‑trial record: call trial counsel to explain the advice, and articulate in detail what the defendant would have said and how it would have changed the case.
• Trial judges’ on‑the‑record colloquies confirming that the defendant understands the right to testify and personally declines are powerful evidence against later IAC claims.

For practitioners, this means that:

• Trial counsel should ensure the record reflects that the decision on testifying is the client’s informed choice.
• Appellate counsel raising IAC on this ground must be prepared to present evidence beyond the defendant’s bare assertion of disagreement.

C. Expert Discovery and Forensic Testimony

The opinion’s most concrete doctrinal clarification lies in its application of OCGA § 17‑16‑4(a)(4):

• It distinguishes between:
  • Case‑specific expert opinions based on tests, examinations, or experiments (which require disclosure), and
  • General explanatory testimony about scientific or forensic principles derived from an expert’s training and experience (which does not).
• By approving the admission of the medical examiner’s generic description of wound types without prior written “reports,” the Court reinforces a relatively narrow reading of the statute, consistent with Green.

Implications for practice:

• Prosecutors are not obligated, under § 17‑16‑4(a)(4), to reduce to writing every anticipated line of general background or educational testimony from an expert.
• Defense counsel, however, should remain vigilant: when an expert’s testimony begins to veer from general principles to case‑specific application (for example, “this particular wound is consistent with a graze gunshot”), disclosure obligations may be triggered.
• Trial courts will likely continue to draw this line: they may exclude undisclosed case‑specific opinions while allowing general background testimony.

D. Evidentiary Objections and Harmless Error

The Court’s handling of the redirect-examination issue illustrates its reluctance to reverse criminal convictions for minor, cumulative evidentiary rulings:

• Even where some doubt exists about the scope of redirect, if the contested testimony is brief and simply reinforces facts proven by other, uncontested evidence, reversal is unlikely.
• This places a premium on defense counsel not only to object, but to ensure that truly damaging testimony is not cumulative—and to highlight prejudice concretely on appeal.

VII. Conclusion

Dixon v. State does not dramatically reshape Georgia criminal law, but it consolidates and clarifies several important principles:

• On sufficiency review, Georgia’s high court is firmly committed to deference under Jackson v. Virginia, especially where the jury has rejected self-defense in the face of conflicting eyewitness accounts.
• Defendants who claim ineffective assistance based on an alleged misadvice not to testify face a steep uphill battle unless they develop a detailed evidentiary record explaining both counsel’s reasoning and the substance of the foregone testimony.
• Harmless-error doctrine continues to operate robustly to insulate convictions from reversal for minor, cumulative evidentiary rulings.
• Most significantly, the Court confirms that OCGA § 17‑16‑4(a)(4)’s expert-report disclosure requirement does not extend to general explanatory forensic testimony not based on case-specific tests or examinations, aligning with and extending Green v. State to medical examiner testimony about wound typology.

For trial practitioners, Dixon underscores the need to:

• Build or contest self-defense claims with careful attention to the defendant’s role as potential aggressor.
• Document strategic advice regarding the defendant’s right to testify.
• Understand the boundaries of expert-disclosure obligations and the difference between case‑specific and general expert testimony.

Within the broader Georgia jurisprudence, Dixon v. State is best understood as a reaffirmation and nuanced application of existing doctrine to a familiar but challenging fact pattern: a fatal confrontation over a romantic dispute, framed at trial through competing narratives of self-defense and aggression, and litigated on appeal through the lenses of sufficiency, strategy, and evidentiary procedure.