¶1NOTICE: 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.
¶2In the Supreme Court of Georgia
¶3 Decided: March 4, 2025
¶4 S24A1237. CALLAWAY v. THE STATE.
¶5 PINSON, Justice.
¶6 Mikeal Callaway was charged with malice murder and other
¶7crimes after going on an early morning shooting spree in his SUV. A
¶8jury convicted him on all counts, and he now appeals his convictions
¶9on numerous grounds. 1 For the reasons set out below, we affirm his
¶10 1 Callaway was indicted on May 10, 2018, in DeKalb County for crimes
¶11related to the DeKalb pair of shootings. The charges were for malice murder (Count 1), two alternative counts of felony murder (Counts 2-3), seven counts of aggravated assault (Counts 4-10), possession of a firearm by a convicted felon (Counts 11), two counts of possession of a firearm during the commission of a felony (Counts 12-13), and fleeing a police officer (Count 14). The jury returned a guilty verdict on all counts following trial on January 27 through January 30, 2020. Callaway was sentenced to life without parole for malice murder. The two counts of felony murder were vacated by operation of law, and one count of aggravated assault (Count 4) merged with the malice murder count. He was further sentenced to 20 years on each remaining count of aggravated assault (Counts 5-10), with each sentence consecutive to the prior count, and 12 months of probation for the fleeing count consecutive to the aggravated assault counts. Callaway timely moved for a new trial, raising the same claims that he now raises before this Court. The trial court denied his motion for new trial. Callaway timely appealed to this Court, and the case was docketed to the August 2024 term of this Court and submitted for a decision on the briefs. convictions.
¶12 1. The shooting spree spanned five miles, four hours, and two
¶13counties (Fulton and DeKalb) beginning late on February 21, 2018
¶14and continuing into the early morning hours of February 22, 2018.
¶15The evidence of each of the shootings (four in total) is recounted be-
¶16low, viewed in the light most favorable to the jury’s verdicts.
¶17 (a) The Diggs Shooting — Fulton County
¶18 Nathaniel Diggs was working as a cook in Atlanta at the time
¶19of the shooting. On the night of February 21, 2018, he got off work
¶20at 11:30 p.m. To go home, he took I-20. While driving, he saw bright
¶21headlights in his mirrors, “like somebody had the high beams right
¶22behind [him].” Diggs moved over a lane to let the vehicle pass, and
¶23an SUV pulled up alongside him.
¶24 Suddenly Diggs’s window burst. He testified that he did not
¶25know what was happening, but he pulled over to the shoulder of the
¶26highway. When he did, he realized he had been shot, so he got in the
¶27back of his car and laid down. A passerby called 911, and EMS and
¶28police arrived. After being taken to the hospital, Diggs was told that
¶29 2 he had been shot nine times — in his stomach, back, and both legs.
¶30Based off the time he left work, Diggs estimated that he was shot
¶31around midnight.
¶32 (b) The Fisher Shooting — Fulton County
¶33 Around 2:00 a.m., Tracy Fisher was driving to his apartment.
¶34He exited I-20 onto Fulton Street in Atlanta. While leaving the in-
¶35terstate, he saw a silver, Infiniti SUV exit behind him. Fisher kept
¶36driving and eventually came to a stop sign. While stopped, Fisher
¶37looked to his right and saw that the SUV had pulled alongside him.
¶38The driver of the SUV “look[ed] at him” and “stare[d] at him.” Fisher
¶39testified that the driver did not “look in a normal state.” Seeing the
¶40strange behavior of the other driver, Fisher accelerated to get away.
¶41 As soon as he accelerated, Fisher heard shots come from the
¶42SUV. He turned his head while driving away and saw the shooter’s
¶43face and the muzzle flash of the gun. One of the bullets then struck
¶44Fisher, ultimately paralyzing him from the chest down. Unable to
¶45control his car, he collided with a parked vehicle and his car flipped
¶46onto its side. Police and EMS arrived a few minutes later.
¶47 3 Police recovered shell casings and a magazine from the scene.
¶48Several hours after the shooting, they were able to conduct a photo
¶49lineup with Fisher, who was then recovering in the hospital. From
¶50the lineup, Fisher identified Callaway as the person who looked
¶51most like the shooter. Fisher identified Callaway as the shooter at
¶52trial.
¶53 (c) The Bankston Shooting — DeKalb County
¶54 Nicholas Bankston was celebrating his birthday with his fam-
¶55ily in the early morning hours of February 22. He and his fiancée
¶56left his mom’s home shortly after midnight. They first went to his
¶57aunt’s home to pick up some of Bankston’s younger siblings, and
¶58then they went to pick up other siblings from his brother’s home. A
¶59few hours later, he drove the group back to his mom’s home. His
¶60fiancée, Abby, was in the passenger seat, and his five siblings —
¶61A.L., N.B., C.L., Z.B., and S.L. — were in the backseats. When the
¶62group got to his mother’s gated subdivision shortly before 3:30 a.m.,
¶63they could not get the entry gate to open, so they went to the en-
¶64trance on the other side of the complex to see if their gate key would
¶65 4 work there.
¶66 When they got to the other entrance, a silver SUV pulled up on
¶67the driver’s side of Bankston’s car, about 10 feet away. Shots came
¶68through the SUV’s passenger window and struck the driver’s side
¶69door and window of Bankston’s car. The children in the backseat
¶70ducked to the floor. Abby was not hit. But Bankston was struck in
¶71the head by a bullet. By the time paramedics arrived, he was dead.
¶72 One of Bankston’s siblings testified that the group did not see
¶73the other car or where the shots were coming from. But another wit-
¶74ness, Bobby Frazier, saw everything. He was delivering newspapers
¶75that morning, and he saw the shooting unfold along his route. He
¶76testified that the vehicle that came up to the Bankston car and from
¶77which shots were fired was a silver Infiniti SUV with a dealer tag.
¶78When he saw and heard the shots, he sped up to leave the area. A
¶79few moments later, the SUV passed Frazier and turned down an-
¶80other road. At that point, Frazier went back to the scene of the shoot-
¶81ing, where he called police and gave a statement once they arrived.
¶82Police spoke to the witnesses at the scene and put out a BOLO for a
¶83 5 silver Infiniti SUV.
¶84 (d) The McMillon Shooting — DeKalb County
¶85 Darryl McMillon was driving to catch a commuter shuttle
¶86around 4:45 a.m. on February 22. As he drove down Gresham Road,
¶87he saw a vehicle parked just off the road. At first, he thought it might
¶88be a police car doing speed checks. As he passed the vehicle, he saw
¶89that it was a silver SUV. Then he heard gunshots. McMillon testified
¶90that his instincts as an Army veteran kicked in, and he crouched
¶91down as he continued to drive — unsure where the shots were com-
¶92ing from or if they were directed at him. He did not hear any glass
¶93breaking or any other noise to indicate his vehicle had been hit, so
¶94he kept driving and went about his day.
¶95 While continuing to drive, the low tire pressure indicator came
¶96on in McMillon’s car, but he assumed this was caused by the cold
¶97weather. That evening on his way home, McMillon’s tire blew out.
¶98Roadside assistance came, changed the tire, and McMillon com-
¶99pleted his journey home. It wasn’t until several days later that
¶100McMillon noticed what appeared to be bullet holes on the side of his
¶101 6 car. He then contacted his brother-in-law, who worked as a narcotics
¶102detective in another town. On his brother-in-law’s advice, McMillon
¶103reached out to DeKalb County police and then to a homicide detec-
¶104tive at the department. McMillon had seen coverage of the other
¶105shootings on the news and realized that it might have been the same
¶106person who shot at his car.
¶107 (e) The Aftermath
¶108 After the McMillon shooting, Callaway went to a Walmart
¶109shortly after 6:00 a.m. Surveillance video from the store shows that
¶110he arrived in a silver SUV, bought several cans of spray paint, and
¶111left in the same SUV. Callaway appears to have spray painted the
¶112SUV black in an attempt to cover up the shootings. A Walmart re-
¶113ceipt for the spray paint was found in the hastily painted SUV, a
¶114GBI fingerprint expert testified that Callaway’s prints matched
¶115those on a spray-paint can’s cap found in the SUV, and fourteen cans
¶116of black spray paint were found in the garbage can at Callaway’s
¶117mom’s home.
¶118 Sometime after Callaway painted the SUV, police were able to
¶119 7 track the vehicle through the manufacturer’s GPS locator service.
¶120The GPS led them to Callaway’s mother’s home. The police chose not
¶121to approach the home or vehicle initially, instead staking out the
¶122location and staging uniformed officers nearby in case someone tried
¶123to flee. Eventually, Callaway and his girlfriend, Keshun Booker,
¶124came out of the home and got into the now-black SUV. When they
¶125started driving, Callaway noticed police and accelerated rapidly.
¶126Marked police cruisers activated their sirens and lights and pursued
¶127Callaway’s vehicle. Shortly after the pursuit began, Booker jumped
¶128out of the moving SUV. Callaway then led police on a chase that
¶129exceeded speeds of 100 miles per hour, but police were eventually
¶130able to immobilize the SUV and arrest Callaway. A 9mm handgun
¶131was found on the floor on the driver’s side of the car. A later search
¶132of the vehicle also turned up the spray paint cap, Walmart receipt,
¶133live ammunition for an AR-15, two spent rifle casings, and a 9mm
¶134pistol.
¶135 An expert witness for the State testified that particles con-
¶136sistent with gunshot residue were found on Callaway’s hands, on his
¶137 8 shirt, and in the car. Another expert testified that the 9mm bullets
¶138found at the Fisher shooting matched the gun found in Callaway’s
¶139car.
¶140 Booker was interviewed by police. She gave a written and audio
¶141recorded statement. In these statements, she told police that she
¶142had been with Callaway during the night while he carried out the
¶143shootings. She said that she would cover herself with a hoodie and
¶144try to remain still so that she would not be shot. Booker also testified
¶145that Callaway was high on Adderall and “X pills.” He would get par-
¶146anoid when high, and that is what provoked him to shoot at other
¶147drivers. She also said that Callaway would beat her when he was
¶148high.
¶149 At trial, Booker admitted to seeing the silver Infiniti SUV the
¶150day before the shootings and that it was spray-painted black the
¶151next day, but she refused to say who painted it. She also admitted
¶152to jumping out of the SUV when Callaway ran from police. But she
¶153recanted her testimony about the shootings, saying that she only
¶154made her earlier statements because she was told she would go to
¶155 9 jail and have her children taken from her if she didn’t corroborate
¶156the police department’s version of events. The State impeached her
¶157testimony with her prior statements to police and prior statements
¶158made during an interview with the prosecutor and an investigator
¶159with the District Attorney’s Office. The State also introduced testi-
¶160mony that Booker had not cooperated with its subpoena and that
¶161she was being held in jail on a material-witness warrant.
¶162 2. Callaway claims that the evidence was not sufficient as a
¶163matter of constitutional due process to authorize a jury to find him
¶164guilty of several of his crimes. Evidence is sufficient as a matter of
¶165due process if, viewed in the light most favorable to the verdict, a
¶166rational trier of fact could have found “the essential elements of the
¶167crime beyond a reasonable doubt.” McCullum v. State, 318 Ga. 485,
¶168489 (2) (a) (899 SE2d 171) (2024) (quoting Jackson v. Virginia, 443
¶169U.S. 307, 319 (99 SCt 2781, 61 LE2d 560) (1979)).
¶170 (a) Callaway contends that the evidence was not sufficient to
¶171authorize a jury to find him guilty of four counts of aggravated as-
¶172 10 sault for four of the children in the backseat of the car. The indict-
¶173ment alleged that Callaway committed aggravated assault against
¶174each of these victims by “shooting at or in the direction of” each of
¶175them. Callaway argues that the evidence only showed that he shot
¶176from close range at the driver’s door and its window — not in the
¶177direction of the car’s rear seats. Because he did not shoot “at or in
¶178the direction of” those in the backseat, Callaway argues, the State’s
¶179evidence was not sufficient to prove the facts alleged in the indict-
¶180ment.
¶181 This claim fails. The evidence showed that Callaway shot at
¶182the car the children were riding in. The jury was authorized to con-
¶183clude that by firing a gun repeatedly into the car, causing the chil-
¶184dren in the backseat to duck to the floor, Callaway used a “deadly
¶185weapon” in a way that placed the children in “reasonable apprehen-
¶186sion of immediately receiving a violent injury,” even though he later
¶187claimed that he was only shooting towards the front seat of the car.
¶188OCGA §§ 16-5-20 (a) (2) & 16-5-21 (a) (2) (aggravated assault with a
¶189deadly weapon).
¶190 11 (b) Callaway also challenges the sufficiency of the evidence as
¶191to venue for his conviction of aggravated assault against McMillon.
¶192He contends that no one with personal knowledge testified to the
¶193location of the shooting, Gresham Road, being in DeKalb County. He
¶194argues that an Atlanta Police Department detective who testified
¶195about venue did not investigate the Gresham Road shooting himself.
¶196Because no one else with personal knowledge testified to venue,
¶197Callaway contends, the State failed to meet its burden in proving
¶198venue.
¶199 This claim fails. Even putting aside the detective’s testimony,
¶200other evidence was sufficient to authorize the jury to conclude be-
¶201yond a reasonable doubt that venue was proper in DeKalb County.
¶202There was evidence that McMillon went to the DeKalb County police
¶203department to file a report about his car being shot, and those police
¶204officers were the ones who came to inspect his vehicle. See Smith v.
¶205State, 295 Ga. 283, 288 (2) (759 SE2d 520) (2014) (noting that evi-
¶206dence of which police department responded to a crime can help es-
¶207 12 tablish venue). And Frazier separately testified that his paper deliv-
¶208ery route was in DeKalb County and that this route took him down
¶209Gresham Road — the road where the McMillon shooting occurred.
¶210Taken together, this evidence was enough to authorize the jury to
¶211find beyond a reasonable doubt that venue was proper in DeKalb
¶212County. See Worthen v. State, 304 Ga. 862, 865 (3) (a) (823 SE2d
¶213291) (2019) (“The State may meet its burden [to prove venue] at trial
¶214using either direct or circumstantial evidence.”).
¶215 3. Callaway contends that evidence of the Fulton County
¶216crimes should have been excluded under OCGA § 24-4-404 (b) (Rule
¶217404 (b)), which limits the admission of “[e]vidence of other crimes,
¶218wrongs, or acts,” which is sometimes called “extrinsic” or “other-
¶219acts” evidence. Roberts v. State, 315 Ga. 229, 235-236 (2) (a) (880
¶220SE2d 501) (2022). But those limits do not apply to “intrinsic” evi-
¶221dence. Id. The line between “extrinsic” and “intrinsic” evidence is not
¶222always bright, but the basic distinction is whether the evidence may
¶223be understood as “direct evidence of the charged crime” or only “evi-
¶224 13 dence of other crimes subject to Rule 404 (b).” Id. at 236 (2) (a) (cita-
¶225tion and punctuation omitted) (emphasis in original). That said,
¶226even evidence of other crimes is still intrinsic if it is (1) evidence of
¶227“an uncharged offense arising from the same transaction or series of
¶228transactions as the charged offense,” (2) “necessary to complete the
¶229story of the crime,” or (3) “inextricably intertwined with” the evi-
¶230dence of the charged offense. Id. In applying this standard, we have
¶231also said that evidence that has to do with “the chain of events ex-
¶232plaining the context, motive, and set-up of the crime” is properly ad-
¶233mitted as intrinsic evidence if it is “linked in time and circumstances
¶234with the charged crime, or forms an integral and natural part of an
¶235account of the crime, or is necessary to complete the story of the
¶236crime for the jury.” Harris v. State, 310 Ga. 372, 378 (2) (b) (850 SE2d
¶23777) (2020) (cleaned up). We review the admission of intrinsic evi-
¶238dence for an abuse of discretion. Abbott v. State, 311 Ga. 478, 483 (2)
¶239(858 SE2d 696) (2021).
¶240 Applying this standard here, the trial court did not abuse its
¶241discretion in admitting the evidence of the Fulton County shootings
¶242 14 as intrinsic evidence. Callaway went on a shooting spree within a
¶243tight geographic and temporal span — five miles and four hours.
¶244Evidence relating to the identification of Callaway as the shooter
¶245came from the victims of the Fulton County shootings. And the in-
¶246vestigation of the crimes and arrest of Callaway were undertaken
¶247jointly by DeKalb and Fulton law enforcement agencies. Because the
¶248evidence related to the Fulton County shootings is linked closely in
¶249time and circumstance and is an integral and natural part of the
¶250story of Callaway’s shooting spree, the trial court did not abuse its
¶251discretion in admitting it. See Brown v. State, 307 Ga. 24, 29 (2) (834
¶252SE2d 40) (2019) (evidence of an uncharged burglary committed in
¶253the same week as the charged crimes was intrinsic to the charged
¶254crimes because it was part of the same “crime spree”).
¶255 Callaway contends that the evidence was not intrinsic because
¶256it was not needed to prove the crimes he was charged with. But “[i]n
¶257assessing whether evidence is necessary in this context, we have
¶258noted that ‘necessary’ is not used in a strictly literal sense, but ra-
¶259ther, refers to what evidence is reasonably necessary for the State
¶260 15 to complete the story of the crime.” Jennings v. State, 318 Ga. 579,
¶261584 (1) (899 SE2d 210) (2024) (citation and punctuation omitted).
¶262And here, there is little question that evidence of part of a shooting
¶263spree within this relatively brief span of time and location is im-
¶264portant context that is reasonably necessary to explain to the jury
¶265how the crimes at issue unfolded. Heade v. State, 312 Ga. 19, 26 (3)
¶266(860 SE2d 509) (2021) (holding that other crimes committed during
¶267defendant’s crime “spree” were “reasonably necessary to complete
¶268the story for the jury”).
¶269 Callaway finally contends that the trial court erred by not giv-
¶270ing a contemporaneous limiting instruction to the jury about the
¶271Fulton County evidence. Although “a limiting instruction generally
¶272is not warranted for intrinsic evidence,” Anderson v. State, 313 Ga.
¶273178, 183 (3) (a) (869 SE2d 401) (2022), here the trial court gave a
¶274limiting instruction, albeit at the close of evidence. Callaway offers
¶275no authority for the idea that a contemporaneous instruction was
¶276required when an instruction was ultimately given, and we are
¶277aware of none.
¶278 16 4. Callaway contends that the State committed prosecutorial
¶279misconduct in a few instances, but these claims are not preserved
¶280for appellate review.
¶281 (a) Callaway contends that the prosecutor put facts not yet in
¶282evidence before the jury in the guise of questions in violation of
¶283Rules 3.7 (a) and 3.8, Comment 1 of the Georgia Rules of Profes-
¶284sional Conduct2 and impermissibly commented on the veracity of a
¶285 2 Rule 3.7 (a) states that:
¶286 A lawyer shall not act as advocate at a trial in which the lawyer is likely to be a necessary witness except where: (1) the testimony relates to an uncontested issue; (2) the testimony relates to the nature and value of legal services rendered in the case; or (3) disqualification of the lawyer would work substantial hardship on the client.
¶287 Rule 3.8, Comment 1 provides that
¶288 A prosecutor has the responsibility of a minister of justice and not simply that of an advocate. This responsibility carries with it specific obligations to see that the defendant is accorded procedural justice and that guilt is decided upon the basis of sufficient evidence. Precisely how far the prosecutor is required to go in this direction is a matter of debate and varies in different jurisdictions. Many jurisdictions have adopted the ABA Standards of Criminal Justice Relating to the Prosecution Function, which in turn are the product of prolonged and careful deliberation by lawyers experienced in both criminal prosecution and defense. Applicable law may require other measures by the prosecutor and knowing disregard of those obligations or a systematic abuse of prosecutorial discretion could constitute a violation of Rule 8.4: Misconduct.
¶289 17 witness in front of the jury. These claims are waived: Callaway did
¶290not object to this line of questioning at trial, and claims of prosecu-
¶291torial misconduct are not subject to review for plain error.3 See Gris-
¶292som v. State, 296 Ga. 406, 411-412 (3) (768 SE2d 494) (2015).
¶293 (b) Callaway claims that the prosecutor engaged in improper
¶294closing argument because his closing argument was “pure emotion-
¶295alism.” This claim is also waived because Callaway did not object to
¶296the closing argument at trial, see Grier v. State, 305 Ga. 882, 887 (3)
¶297(828 SE2d 304) (2019), and claims that improper statements were
¶298made in closing argument are not subject to review for plain error.
¶299Simmons v. State, 299 Ga. 370, 372-373 (2) (788 SE2d 494) (2016).
¶300 5. Callaway raises a pair of claims that his trial counsel’s as-
¶301sistance was constitutionally ineffective. To prevail on a claim of in-
¶302effective assistance of counsel, Callaway must show that his trial
¶303counsel performed deficiently and that the deficiency prejudiced
¶304him. See Strickland v. Washington, 466 U.S. 668, 687 (III) (104 SCt
¶305 3 Callaway does not appear to claim that the trial court erred in admit-
¶306ting evidence, only that the prosecutor’s conduct was improper. 18 2052, 80 LE2d 674) (1984). To show deficiency, Callaway must es-
¶307tablish that counsel “performed his duties in an objectively unrea-
¶308sonable way, considering all the circumstances and in light of pre-
¶309vailing professional norms.” Evans v. State, 315 Ga. 607, 611 (2) (b)
¶310(884 SE2d 334) (2023). And the law “recognizes a ‘strong presump-
¶311tion’ that counsel performed reasonably, and the defendant bears
¶312the burden of overcoming this presumption.” Id. An attorney’s deci-
¶313sions as to what evidence to present is “a matter of trial strategy,”
¶314and “such decisions will form the basis for an ineffectiveness claim
¶315only if they were so patently unreasonable that no competent attor-
¶316ney would have followed such a course.” Id. at 611 (2) (c) (cleaned
¶317up). To show prejudice, Callaway “must establish a reasonable prob-
¶318ability that, in the absence of counsel’s deficient performance, the
¶319result of the trial would have been different.” Rashad v. State, 318
¶320Ga. 199, 208 (3) (897 SE2d 760) (2024) (cleaned up). If Callaway
¶321“fails to make a sufficient showing on one part of the Strickland test,
¶322we need not address the other part.” Starks v. State, 320 Ga. 300,
¶323304 (2) (908 SE2d 614) (2024) (citing Rashad, 318 Ga. at 208 (3)).
¶324 19 (a) Callaway contends that his counsel rendered ineffective as-
¶325sistance by failing to object to the prosecutor’s closing argument.
¶326Some of the statements that Callaway argues warranted objection
¶327include: “[t]his man put a bullet in [Bankston’s] head, and he de-
¶328prived that family of him for the rest of their lives”; “you’re going to
¶329hold him responsible for that”; and “[y]ou’re going to find Mikeal
¶330Callaway guilty because you’re going to hold him responsible for
¶331tearing Mr. Bankston away from his family. Because he was a good
¶332man, and he did nothing to deserve what Mikeal Callaway did to
¶333him.”
¶334 Counsel’s failure to object to these comments during argument
¶335was not deficient performance because those comments were not im-
¶336proper. Cochran v. State, 305 Ga. 827, 834 (2) (d) (828 SE2d 338)
¶337(2019). Prosecutors “may forcibly or even extravagantly attempt to
¶338impress upon the jury the enormity of the offense and the solemnity
¶339of their duty.” Nundra v. State, 316 Ga. 1, 11 (4) (b) (885 SE2d 790)
¶340(2023) (citation and punctuation omitted). That is all that the pros-
¶341ecutor did here. He impressed upon the jury the gravity of the crime
¶342 20 — particularly the murder of Bankston — and told them it was their
¶343duty to do justice. This argument fell well within the “wide latitude”
¶344that prosecutors are given in closing argument. Summerville v.
¶345State, 320 Ga. 60, 62 (2) (907 SE2d 604) (2024) (citation omitted).
¶346 (b) Callaway contends that his counsel rendered ineffective as-
¶347sistance by failing to object to the prosecutor vouching for a witness’s
¶348credibility during questioning. 4 Callaway specifically points to state-
¶349ments made during the impeachment of Booker that he contends
¶350boosted her earlier statement’s credibility:
¶351 Q. And do you remember I said, but I don’t think you did any of that? A. Right, because I didn’t. Q. Right. And I told you I believed you were telling me what? A. The truth. Q. That’s what I asked you to do; right? A. Yes.
¶352 4 Callaway’s brief refers to this claim as ineffectiveness for failure to ob-
¶353ject to “improper bolstering.” But “bolstering” refers to a specific scenario in our law — when a witness testifies about the credibility of another witness. See Brown v. State, 302 Ga. 454, 460-461 (2) (b) (807 SE2d 369) (2017) (“When a witness’s statement does not directly address the credibility of another witness, however, there is no improper bolstering.”). Callaway’s argument focuses instead on the prosecutor’s statements about a witness’s credibility, which is not a true “bolstering” claim. So we address the substance of his argument that counsel was ineffective for failing to object to the prosecutor’s line of questioning about the witness’s credibility. 21 Counsel was not deficient in failing to object to this line of ques-
¶354tioning. We have said that “decisions regarding trial tactics and
¶355strategy may form the basis for an ineffectiveness claim only if they
¶356were so patently unreasonable that no competent attorney would
¶357have followed such a course.” Bates v. State, 313 Ga. 57, 62 (2) (867
¶358SE2d 140) (2022) (citation omitted). In these circumstances, it would
¶359not be unreasonable for trial counsel to decide as a matter of trial
¶360strategy to avoid objecting to questions posed while the State im-
¶361peached its own witness. Objections could distract the jury from the
¶362witness’s credibility issues. Objections could also give the jury the
¶363impression that the defense did not want the prior inconsistent
¶364statements to be admitted because they were the truthful account of
¶365events. And the alleged misconduct was brief and not the focus of
¶366the questioning. So we cannot say that no reasonable lawyer would
¶367fail to object in these circumstances.
¶368 6. Callaway contends that the cumulative effect of errors at
¶369trial denied him a fundamentally fair trial. This claim fails because
¶370 22 he has not established any error. See Wynn v. State, 313 Ga. 827,
¶371840 (6) (874 SE2d 42) (2022).
¶372 Judgment affirmed. All the Justices concur.
¶373 23