Justia Georgia Supreme Court Opinion Summaries

Allen Turner died from surgical complications, leading his daughter, Norkesia Turner, to sue Drs. William Thompson and Heather Nolan, and their employer, the Medical Center of Central Georgia, Inc. (MCCG), for medical malpractice and wrongful death. The jury awarded Turner approximately $7.2 million in noneconomic damages for wrongful death. MCCG moved to reduce this award to the statutory cap of $350,000 under OCGA § 51-13-1 (b) and (c), but the trial court denied the motion, citing the Georgia Supreme Court's decision in Atlanta Oculoplastic Surgery, P.C. v. Nestlehutt, which found such caps unconstitutional.MCCG appealed to the Court of Appeals, which affirmed the trial court's decision, reasoning that the Nestlehutt decision foreclosed MCCG's argument. The Court of Appeals held that the $7.2 million award did not need to be reduced to the statutory cap. MCCG then petitioned the Supreme Court of Georgia for a writ of certiorari, which was granted to address whether the Court of Appeals properly applied the precedent regarding the constitutional right to trial by jury.The Supreme Court of Georgia did not decide whether the application of OCGA § 51-13-1’s caps to the $7.2 million award would violate Turner’s constitutional right to a jury trial. Instead, it found that the lower courts had not applied the correct analytical framework from Nestlehutt to the wrongful death claim. The Supreme Court clarified that the holding in Nestlehutt was specific to medical malpractice claims and did not control the issue in this case. Consequently, the Supreme Court vacated the decision of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "THE MEDICAL CENTER OF CENTRAL GEORGIA, INC. v. TURNER" on Justia Law

John Padgett was convicted of malice murder for the strangling death of his former girlfriend, Wynesha Medley. Medley ended their relationship in November 2016, after which Padgett sent her aggressive messages and visited her apartment uninvited. On January 23, 2017, Medley reported to the police that she believed Padgett had turned off her power. The next day, Medley was found dead in her apartment with a pair of leggings around her neck. Forensic evidence linked Padgett to the crime scene, including his DNA under Medley’s fingernails and cell phone location data placing him near her apartment at relevant times.A Chatham County grand jury indicted Padgett for malice murder, felony murder, and aggravated assault. In May 2021, a jury found him guilty on all counts, and he was sentenced to life in prison without parole. Padgett filed a motion for a new trial, which was denied after a hearing in September 2024. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Padgett’s claims of ineffective assistance of counsel. Padgett argued that his trial counsel failed to emphasize certain DNA evidence, investigate and present evidence about another potential suspect, and object to the prosecutor’s statements during closing arguments. The court found that the decisions made by Padgett’s trial counsel were strategic and not deficient. Additionally, Padgett failed to show that the outcome of his trial would have been different if his counsel had acted differently. The court concluded that Padgett did not demonstrate prejudice from his counsel’s performance and affirmed the conviction. View "PADGETT v. THE STATE" on Justia Law

Keitran Foots was convicted of malice murder and other offenses related to the shooting death of Sharika Bowman. The incident occurred on March 30, 2018, and Foots was indicted in October 2018. The charges included malice murder, two counts of felony murder, aggravated assault family violence, possession of a firearm by a convicted felon, and possession of a firearm during the commission of a felony. The jury found Foots guilty on all counts, and he was sentenced to life in prison without the possibility of parole for malice murder, along with concurrent terms for the other offenses.Foots filed a motion for a new trial, which was denied by the trial court. He then filed a timely notice of appeal. The Supreme Court of Georgia reviewed the case, focusing on two claims of error related to the trial court's handling of a voluntary manslaughter instruction and the sufficiency of the evidence supporting his convictions. The court noted that any challenge to the felony murder counts was moot because those counts were vacated by operation of law when the trial court entered a sentence on the malice murder count.The Supreme Court of Georgia held that the evidence presented at trial was sufficient to support Foots's convictions. The court emphasized that the jury was authorized to reject Foots's self-defense claim based on his testimony and the corroborative evidence, including his actions after the shooting, such as fleeing the scene and leading police on a high-speed chase. The court affirmed the judgment, concluding that the evidence was sufficient to support the convictions for malice murder, aggravated assault family violence, and firearms offenses. View "FOOTS v. THE STATE" on Justia Law

Taj Dialo Gayle was convicted of felony murder predicated on kidnapping in connection with the shooting death of Melanie Steele. Steele was killed on September 13, 2019. Gayle, along with John Bailey, Justin Path, and Marcus Wilson, was indicted for various crimes related to Steele’s death. Gayle faced charges including felony murder, kidnapping, armed robbery, and possession of a firearm during the commission of a felony. Wilson pleaded guilty to reduced charges and testified against Gayle. The State dropped the armed robbery and firearm charges before trial. At the joint trial of Gayle and Bailey, the jury found Gayle guilty of felony murder and kidnapping. The trial court merged the kidnapping charge into the felony murder charge and sentenced Gayle to life in prison without parole.Gayle filed a motion for a new trial, which was denied by the trial court. He then appealed to the Supreme Court of Georgia, arguing that the evidence was insufficient because Wilson’s testimony, as an accomplice, was not corroborated.The Supreme Court of Georgia affirmed the conviction. The court held that the jury could have reasonably found that Wilson was not an accomplice, as his testimony indicated he was unaware of the plan to kidnap and shoot Steele until it happened. The court noted that when the issue of whether a witness was an accomplice is submitted to the jury and there is evidence allowing the jury to find that the witness was not an accomplice, corroborating evidence is not required to sustain a guilty verdict. Therefore, the evidence was sufficient to support Gayle’s conviction. View "GAYLE v. THE STATE" on Justia Law

Andrew Wilson was convicted of malice murder and other crimes related to the asphyxiation and burning of Gregory Harris. Wilson appealed, arguing that the trial court improperly admitted evidence of a prior armed robbery he committed. The Supreme Court of Georgia reviewed the case.Initially, a Fulton County grand jury indicted Wilson and Edgar Hubbard for multiple crimes, including malice murder and arson. Hubbard was tried first and convicted of arson. Wilson was tried separately and found guilty on all counts. He was sentenced to life without parole for malice murder, with additional concurrent sentences for arson and theft by receiving stolen property. Wilson's motion for a new trial was denied, leading to this appeal.The Supreme Court of Georgia found that the trial court abused its discretion by admitting evidence of Wilson’s prior armed robbery under OCGA § 24-4-404 (b). The court determined that this error was not harmless and reversed Wilson’s convictions. However, the court concluded that the evidence was constitutionally sufficient to support the jury’s guilty verdicts on all counts except for theft by receiving stolen property. Therefore, Wilson may be retried on all counts except for theft by receiving.Additionally, the court addressed Wilson’s claim regarding the denial of his motion to suppress evidence derived from his cell phone records. The court found no error in the trial court’s decision to deny the motion to suppress, as the records were obtained in good faith under the Stored Communications Act, which was valid at the time.In summary, the Supreme Court of Georgia reversed Wilson’s convictions due to the improper admission of prior bad act evidence, but allowed for a retrial on all counts except theft by receiving stolen property. The court upheld the trial court’s decision on the admissibility of cell phone records. View "WILSON v. THE STATE" on Justia Law

Abraham Quintanar was convicted of felony murder and other crimes related to the shooting death of Marcus Gilead and the attempted armed robbery of Ciavy Wiles. On February 10, 2020, Quintanar, along with co-indictees Miguel Angel Gonzalez and Sebastian Resendiz-Garcia, attempted to rob Gilead and Wiles at gunpoint. During the robbery, Quintanar and Gilead struggled for control of Quintanar’s gun, resulting in Quintanar shooting and killing Gilead. Quintanar was indicted on multiple charges, including felony murder, aggravated assault, and possession of a firearm. He was tried separately and found guilty on all counts, receiving a life sentence with the possibility of parole for felony murder, among other sentences.The trial court admitted Quintanar’s custodial statement, testimony about a video recording not introduced into evidence, and denied certain impeachment of a witness. The court also refused to give requested jury charges related to justification and mutual combat. Quintanar argued that these decisions, along with portions of the State’s closing argument, amounted to plain error and cumulative prejudice.The Supreme Court of Georgia reviewed the case and found that the trial court did not err in admitting Quintanar’s custodial statement, as it was deemed voluntary under the totality of the circumstances. The court also found that any error in admitting testimony about the video recording was harmless, as it was cumulative of other evidence. Additionally, the court held that the trial court did not abuse its discretion in limiting cross-examination of Resendiz-Garcia and that the evidence did not support Quintanar’s requested jury charges on self-defense and mutual combat.The Supreme Court of Georgia affirmed Quintanar’s convictions but vacated his conviction and sentence for aggravated assault, as it should have merged with his conviction for attempted armed robbery. View "QUINTANAR v. THE STATE" on Justia Law

Terrence Darnell Lee was convicted of felony murder and other crimes related to five incidents in the summer of 2018, including the shooting death of Kemar Hawkins on August 2, 2018. The incidents occurred on July 21, July 25, July 28, July 29, and August 2, 2018. Lee was indicted on multiple counts, including felony murder, home invasion, aggravated assault, armed robbery, and possession of a firearm during the commission of a felony. He was re-indicted on the same counts in February 2020. His first trial in March 2020 ended in a mistrial due to the COVID-19 pandemic. In his second trial in April 2022, the jury found him guilty on all counts.The trial court sentenced Lee to life in prison for felony murder and additional consecutive sentences for other convictions, totaling nine life sentences plus 175 years. Lee's motion for a new trial was denied, and he filed a timely notice of appeal. The Supreme Court of Georgia remanded the case to supplement the record, and the trial court granted the motion. Lee then filed a renewed notice of appeal.The Supreme Court of Georgia affirmed Lee's convictions. The court found that any error in admitting evidence of a prior incident in Florida was harmless. The trial court did not abuse its discretion in denying Lee's motion to sever the counts related to the murder, as the offenses were part of a crime spree. The evidence was sufficient to support Lee's convictions, including those related to the July 25 incident, where the jury could reasonably conclude that the perpetrator had a gun. The trial court was not required to instruct the jury on lesser included offenses, as no evidence supported that Lee committed only the lesser offenses. Any error in allowing a detective to identify Lee in surveillance footage was deemed harmless. The cumulative effect of any errors did not deprive Lee of a fair trial. View "LEE v. THE STATE" on Justia Law

Timothy Coleman, Jr., and Tyriek D. Walker were convicted of criminal contempt for refusing to testify in the trial of Arthur Newton, a fellow gang member accused of ordering the murder of Dominique Powell. Coleman and Walker had previously pleaded guilty to charges related to Powell's death, with Coleman admitting to malice murder and Walker to conspiracy to commit murder. Despite their guilty pleas, both refused to testify at Newton's trial, citing their Fifth Amendment rights against self-incrimination due to potential federal prosecution.In the Chatham County Superior Court, Coleman and Walker were each found guilty of multiple counts of contempt for refusing to answer questions during Newton's trial. Coleman was convicted of 19 counts and sentenced to 380 days in prison, while Walker was convicted of 21 counts and sentenced to 420 days. They appealed these convictions, arguing that the trial court erred in compelling their testimony and that their multiple contempt convictions should merge into a single count.The Supreme Court of Georgia reviewed the case and determined that the trial court erred in requiring Coleman to answer questions about his unsworn proffer, as these could further incriminate him. Consequently, Coleman's contempt convictions related to these questions were reversed. However, the court upheld the trial court's decision to compel answers to questions about the crimes to which they had pleaded guilty and their plea hearings, as these did not place them in additional jeopardy.The Supreme Court of Georgia vacated the remaining contempt convictions and sentences for both Coleman and Walker, ruling that their multiple refusals to testify constituted a single incident of contempt. The case was remanded for the trial court to convict and sentence each appellant for only one count of contempt. View "COLEMAN v. THE STATE" on Justia Law

A woman was convicted of malice murder and related offenses following the death of her four-year-old daughter, who suffered extensive and fatal injuries from prolonged physical abuse. The child lived with her mother, two younger siblings, and the mother’s girlfriend. On the day of the child’s death, neighbors responded to cries for help and found the child unresponsive, with visible injuries. Medical testimony established that the child had been subjected to severe, repeated blunt-force trauma over a period of hours, resulting in a painful death. The mother’s statements to a fellow jail inmate implicated her in restraining the child while her girlfriend beat the child with a wooden object. The girlfriend, who had pleaded guilty to the murder, testified for the defense but minimized her own involvement.After a jury trial in the Superior Court of Clayton County, the mother was found guilty of malice murder and other charges, but acquitted of tampering with evidence and aggravated sexual battery. She was sentenced to life without parole plus consecutive terms for lesser offenses. Her motion for a new trial was denied.On appeal, the Supreme Court of Georgia first addressed whether it should retain jurisdiction over non-death-penalty murder appeals, ultimately deciding to continue exercising jurisdiction over such cases. The court then reviewed the merits of the appeal, rejecting the mother’s arguments that the evidence was insufficient, that her trial counsel was ineffective, that the trial court erred by not instructing the jury on confession corroboration, and that the State failed to correct allegedly false testimony. The court found the evidence sufficient, determined that counsel’s performance was not constitutionally deficient, and concluded that any alleged errors did not affect the outcome. The Supreme Court of Georgia affirmed the convictions and sentences. View "HART v. THE STATE" on Justia Law

Ryan Bowdery, Rashad Barber, and David Wallace were convicted of murder, aggravated assault, and related crimes in connection with the shooting death of Darius Bottoms and the nonfatal shooting of Jared Robinson. The crimes occurred on June 13, 2014, and a Fulton County grand jury indicted the three men in February 2015. They were tried together in December 2017, and Bowdery was found guilty on all counts. He was sentenced to life in prison with the possibility of parole for malice murder, along with additional consecutive terms for other charges. Bowdery filed a motion for a new trial, which was denied, leading to this appeal.The trial court denied Bowdery's motion for a new trial, and he appealed to the Supreme Court of Georgia. Bowdery argued that the evidence corroborating the testimony of an accomplice was insufficient under OCGA § 24-14-8, that the trial court erred in giving an incomplete instruction on accomplice corroboration, and that the trial court abused its discretion by not taking remedial measures after an objection to the State’s closing argument.The Supreme Court of Georgia reviewed the case and found that the evidence, including cell phone records and gang-related evidence, provided sufficient corroboration of the accomplice's testimony. The court also determined that the trial court did not plainly err in its jury instructions regarding accomplice corroboration, as there was no dispute that the witness was an accomplice. Additionally, the court held that the prosecutor's closing argument did not constitute an impermissible argument about future dangerousness and that the trial court did not abuse its discretion in handling the objection. Consequently, the Supreme Court of Georgia affirmed Bowdery's convictions. View "BOWDERY v. THE STATE" on Justia Law