Justia Georgia Supreme Court Opinion Summaries

Benjamin Francis was killed on May 10, 2023, after being shot five times on a sidewalk in Norcross, Georgia. Willie Lee Jones, who uses a wheelchair, was indicted for multiple offenses, including malice murder, felony murder, aggravated assault, and firearm possession. Surveillance footage showed Francis attacking Jones at a convenience store minutes before the shooting, attempting to steal from him with a utility knife. Later, Jones confronted Francis with a pistol, resulting in Francis being shot as he attempted to walk away and then returned toward Jones.A Gwinnett County grand jury indicted Jones for several charges. Jones was tried alone in the Superior Court of Gwinnett County. The jury acquitted him of malice murder but convicted him of felony murder based on aggravated assault and possession of a firearm during the commission of a felony. The trial court sentenced Jones to life imprisonment for felony murder and five consecutive years for the firearm charge. Other guilty verdicts were vacated or merged. Jones timely filed a motion for new trial, which was denied by the Superior Court, and then appealed.The Supreme Court of Georgia reviewed Jones’s claim that the evidence was constitutionally insufficient to support his convictions, arguing self-defense. Utilizing the standard from Jackson v. Virginia, the Court viewed the evidence in the light most favorable to the verdict. The Court held that the evidence authorized the jury to find that Jones did not reasonably believe deadly force was necessary, as Francis was not an imminent threat when shot. The jury was entitled to reject Jones’s claim of self-defense. The Supreme Court of Georgia affirmed the trial court’s judgment. View "JONES v. THE STATE" on Justia Law

The case involves Xavier Bradford, who was indicted on multiple charges related to the shooting death of Keneisha Carr, including felony murder, gang activity, aggravated assault, attempted armed robbery, and firearm possession. Bradford was tried separately in Fulton County in August 2012, where the jury acquitted him of malice murder but convicted him on all remaining counts. He received consecutive sentences, including life imprisonment for felony murder. The trial evidence indicated Bradford was a member of the Red Kartel gang, and linked him to the crime through eyewitness accounts, cell phone records, and text messages suggesting efforts to conceal evidence and avoid police detection.Following his conviction, Bradford’s counsel filed a timely motion for new trial, but resolution was delayed for thirteen years. During this period, Bradford repeatedly requested trial transcripts and made pro se filings, often highlighting his indigence and inability to access records. The trial court denied these requests, mistakenly believing there was no pending post-conviction motion. After numerous changes in counsel and further requests, an amended motion for new trial was ultimately filed in July 2023, raising ineffective assistance of counsel for the first time. The Superior Court of Fulton County held a hearing in April 2025 and denied the motion for new trial.On appeal to the Supreme Court of Georgia, Bradford argued that the evidence was insufficient, the trial court made evidentiary errors, he received ineffective assistance of counsel, and cumulative prejudice warranted a new trial. The Supreme Court held that none of these claims had merit. The evidence was sufficient to support all convictions, evidentiary objections were either unpreserved or properly rejected, and Bradford failed to demonstrate ineffective assistance or cumulative prejudice. The judgment was affirmed. View "BRADFORD v. THE STATE" on Justia Law

Late one night in September 2011, a fight broke out at a nightclub in Augusta between two groups, one of which included the defendant. After security broke up the fight, all patrons were forced to leave the club. As people gathered outside, the defendant was observed getting into a car, displaying a gun, and then firing several shots toward the crowd. One of these shots struck and killed Ashley Brown. Two eyewitnesses later identified the defendant as the shooter. The defendant gave multiple statements to police, initially denying involvement and later claiming another man was responsible. At trial, the defense attempted to implicate another individual, Roosevelt Ellison, as the shooter.After indictment, the case proceeded to trial in the Superior Court of Richmond County. The jury found the defendant guilty on all counts, including felony murder, and the trial court imposed consecutive sentences. The defendant’s post-trial motions were delayed for several years due to changes in counsel and transcript preparation. Ultimately, the trial court denied the defendant’s amended motion for a new trial. The defendant then appealed, raising several issues, including exclusion of hearsay evidence, alleged Brady violations, denial of a continuance, jury instructions, the sufficiency of an indictment count, and ineffective assistance of counsel.The Supreme Court of Georgia reviewed the appeal. It held that the trial court did not abuse its discretion in excluding hearsay statements implicating Ellison because they lacked sufficient guarantees of trustworthiness. The Court found no Brady violation since the defense could have discovered the contested evidence through reasonable diligence. The trial court did not err in denying a continuance, giving the challenged jury instructions, or denying a directed verdict. The Court also found trial counsel’s performance was not constitutionally deficient. The convictions and sentences were affirmed. View "MURPHY v. THE STATE" on Justia Law

The appellant was convicted in 2022 for malice murder and other crimes stemming from two separate incidents. The first incident, in June 2020, involved the aggravated assault of Jamie Delaney, where Delaney’s car was shot at by a man driving a silver Toyota Camry. Although Delaney did not identify Samuels as the shooter, other acquaintances later did. The second incident, in November 2020, involved the shooting death of Kareem Smalls outside an apartment complex in Savannah. Witnesses saw a red Dodge Charger circling the area and fleeing after the shooting; GPS and rental records linked the Charger to Samuels. Ballistics evidence tied both shootings to the same firearm. Samuels admitted to being at the scene of the Smalls shooting and fleeing from police afterward.After a jury trial in the Superior Court of Chatham County, Samuels was found guilty on all counts. The trial court sentenced him to life in prison for malice murder and imposed additional consecutive sentences for other charges. Certain counts were vacated or merged by operation of law. Samuels moved for a new trial, which the trial court denied. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the sufficiency of evidence, evidentiary rulings, and claims of ineffective assistance of counsel. The Court held that the evidence was sufficient to sustain the convictions, noting that the jury was entitled to resolve conflicts and assess witness credibility. The Court found that any assumed error in admitting evidence of drug activity and detective testimony was harmless and did not affect the verdict. The Court also rejected the claim of cumulative error, concluding that the strong evidence against Samuels meant he was not denied a fundamentally fair trial. The judgment was affirmed. View "SAMUELS v. THE STATE" on Justia Law

A man was convicted for the malice murder of his romantic partner, who was found dead from ligature strangulation in her home. The evidence at trial included testimony from a friend who recounted that after the crime, the defendant confessed to strangling the victim and pointed a gun at him while seeking a ride to a remote location. The defendant also made incriminating statements to his brother and left a voicemail for another friend expressing regret. Law enforcement found no signs of forced entry or struggle, and the autopsy revealed fatal neck injuries consistent with asphyxiation. The defendant was arrested two days later and, during a custodial interview, admitted to a fight with the victim but claimed a lack of memory about the incident.A Bibb County grand jury indicted the defendant on charges of malice murder, felony murder, and aggravated assault. After a jury trial, he was convicted on all counts and sentenced to life in prison for malice murder; the felony murder count was vacated by operation of law. The defendant filed a motion for new trial, which the Superior Court of Bibb County denied after a hearing.On appeal, the Supreme Court of Georgia reviewed the trial court’s admission of autopsy photographs and claims of ineffective assistance of counsel. The Supreme Court held that the trial court did not abuse its discretion in admitting the autopsy photographs, as they were relevant to illustrate the nature of the victim’s injuries and support the medical examiner’s testimony, and their probative value was not substantially outweighed by unfair prejudice. The Court also found that trial counsel was not deficient, as objections to the photographs were properly made and preserved. Accordingly, the judgment was affirmed. View "FOURNIER v. THE STATE" on Justia Law

Maria Owens was accused of causing the death of eleven-month-old Jaylen Kelly in 2011, after Jaylen’s parents left him in her care. Jaylen was healthy that morning, but by midday, Owens reported he was having trouble breathing. Emergency personnel transported him to the hospital, where he died. Medical evidence showed Jaylen suffered fatal blunt-force trauma to the torso, likely inflicted intentionally. Owens admitted to “patting” Jaylen on the back but claimed she may have exacerbated a preexisting injury. Expert testimony generally agreed the injury was caused intentionally and would have left Jaylen unable to walk.After her first trial, Owens was acquitted of malice murder but convicted of felony murder, involuntary manslaughter, aggravated assault, and first-degree child cruelty. The trial court sentenced her for involuntary manslaughter and purported to merge the other counts. On appeal, the Supreme Court of Georgia determined the verdicts for crimes with different mental states (intent and negligence) could be mutually exclusive, vacated all convictions, and remanded for a new trial. Subsequently, the Court overruled this mutual exclusivity precedent in Springer v. State, holding that verdicts for both intent and negligence crimes arising from the same act are not categorically mutually exclusive.At Owens’s 2020 retrial, the trial court instructed the jury that it could not convict her of both involuntary manslaughter and intent crimes, contrary to the Supreme Court’s revised doctrine. The jury convicted Owens of felony murder and child cruelty. Reviewing the case, the Supreme Court of Georgia held that the trial court’s instruction was erroneous and harmful as to the homicide charges, warranting reversal of the felony murder conviction. Owens may be retried for felony murder because the evidence was constitutionally sufficient. The conviction for child cruelty stands, but the sentence is vacated pending further proceedings. View "OWENS v. THE STATE" on Justia Law

In this case, the defendant was charged in connection with the shooting death of his girlfriend, with whom he lived. The incident occurred in their shared home, where police found the victim unresponsive from a gunshot wound. The defendant asserted at trial that the victim shot herself and subsequently placed the firearm in a drawer before becoming incapacitated. Evidence at trial included forensic testimony about the gunshot wound, testimony regarding the relationship between the parties, and a letter found in the bedroom that some identified as being in the victim’s handwriting. The physical evidence included the location of the firearm and gunshot residue findings. There was conflicting evidence about the victim’s mental state and the nature of the couple's relationship.A Baldwin County grand jury indicted the defendant for several offenses, including malice murder and felony murder. After a jury trial in the Superior Court of Baldwin County, the defendant was acquitted of malice murder but convicted of felony murder and other related offenses. He received a life sentence without parole and additional years for firearm possession. The defendant moved for a new trial, which was denied by the trial court.Upon appeal to the Supreme Court of Georgia, the defendant argued that the trial court erred by admitting certain expert testimony, misapplied the relevant standard for expert evidence, improperly admitted crime lab reports into the jury room, and that trial counsel provided ineffective assistance. The Supreme Court of Georgia held that the trial court did not abuse its discretion in admitting the expert testimony under the Daubert standard and OCGA § 24-7-702(b), did not err in allowing the jury to review the lab reports, and found no deficient performance by trial counsel. The defendant’s convictions were affirmed. View "CHAPPLE v. THE STATE" on Justia Law

Lucid Group USA, Inc., a company that sells new electric vehicles directly to consumers in other states, sought to open a retail location in Georgia. To do so, it applied for a dealer license from the Georgia Department of Revenue, which is required to sell new motor vehicles in the state. The Department denied Lucid’s application, citing Georgia’s Motor Vehicle Franchise Practices Act provisions that generally prohibit manufacturers and their affiliates from selling new motor vehicles directly to consumers or owning dealerships, thereby requiring sales to go through independent franchised dealers.Following the denial, Lucid filed suit against the State of Georgia, arguing that as applied to Lucid, these statutory provisions violate several sections of the Georgia Constitution, including the Due Process Clause, the Equal Protection Clause, and Article III, Section VI, Paragraph IV. Lucid also sought an injunction against enforcement of the law. The Superior Court permitted the Georgia Automobile Dealers Association to intervene and dismissed Lucid’s complaint. The court found Lucid’s due process and equal protection claims barred by Article III, Section VI, Paragraph II(c), which authorizes the legislature to regulate the motor vehicle industry “notwithstanding” those constitutional protections. The trial court also concluded Lucid had not stated a valid claim under Paragraph IV, reasoning the law was a general law with uniform operation.The Supreme Court of Georgia reviewed the case. It held that Paragraph II(c) does not bar all due process and equal protection challenges, but only those regulations enacted for the purpose of preventing frauds, unfair business practices, unfair methods of competition, impositions, or other abuses upon Georgia’s citizens. The Court vacated the trial court’s dismissal of Lucid’s due process and equal protection claims and remanded for further consideration. The Court affirmed in part and vacated in part the dismissal of Lucid’s Paragraph IV claims, specifically remanding for further proceedings regarding Lucid’s challenge to the 2015 statutory amendment. View "LUCID GROUP USA, INC. v. STATE OF GEORGIA" on Justia Law

The case involves the shooting death of Oshane Scott at his apartment in Lilburn, Georgia. Karre Rivers arranged to meet Scott to purchase marijuana and other controlled substances. After Rivers arrived, he and Scott went upstairs to the apartment, where Wright, Scott’s girlfriend, heard multiple gunshots. Rivers fled the scene, leaving his cell phone behind. Evidence showed Scott had a gun that was damaged and could not have fired the spent shell casings found at the scene. Rivers initially gave conflicting stories to investigators, eventually admitting he shot Scott with his own firearm and disposed of it afterward. Testimony indicated Scott was shot multiple times, including while he was already on the ground.The Superior Court of Gwinnett County indicted Rivers for several charges, including malice murder, felony murder, aggravated assault, and firearm possession. At trial, Rivers was found guilty of four counts; the fifth count was nolle prossed. Rivers was sentenced to life without parole and a consecutive five-year term. He filed a motion for new trial, which was denied without a hearing. Rivers then appealed, arguing that the trial court erred by instructing the jury on excessive force in connection with his self-defense claim.The Supreme Court of Georgia reviewed the appeal. Applying the plain error standard, the court found that the trial court did not commit plain error in giving the excessive force jury instruction. The evidence provided at least slight support for the instruction, as required under Georgia law. Consequently, the Supreme Court of Georgia affirmed the trial court’s judgment. View "RIVERS v. THE STATE" on Justia Law

Donald Carter was convicted of malice murder and other related charges following the shooting death of Samuel Sanders. The incident occurred after Carter, Sanders, and Sanders’s grandson completed a moving job between Philadelphia and Georgia. On their return trip, Carter consumed alcohol, became agitated, harassed Sanders’s grandson, and ultimately shot Sanders while traveling on the highway. Carter fled the scene and was later found by law enforcement asleep in a shed with the firearm. He claimed to have no memory of the events, attributing his blackout to either alcohol or a substance sprayed in his face by Sanders’s grandson.After indictment by the Jackson County grand jury, Carter was tried before the Superior Court of Jackson County, where a jury found him guilty on all counts. The trial court imposed a life sentence for malice murder, merging and vacating some counts as required by law. Carter filed a motion for new trial, which was amended and eventually denied after an evidentiary hearing.The Supreme Court of Georgia reviewed Carter’s appeal, focusing on whether the trial court erred by not conducting a hearing on Carter’s mental competence to stand trial after the Department of Behavioral Health and Developmental Disabilities found him competent. The Court held that, under the applicable statutes, a hearing on competency was only required if a special plea of incompetency was filed, which Carter did not do. The Court also determined that Carter’s counsel was not ineffective for failing to file such a plea, as there was insufficient evidence that a competency trial would have changed the outcome. The Supreme Court of Georgia affirmed Carter’s convictions and the trial court’s rulings. View "CARTER v. THE STATE" on Justia Law