Justia Georgia Supreme Court Opinion Summaries

Deonte Kitchens was convicted of malice murder and other crimes related to the shooting death of Alveno Culver. Kitchens was indicted in November 2015 and tried alone in September 2016, where the jury found him guilty on all counts. He was sentenced to life in prison without parole for malice murder, along with additional consecutive and concurrent sentences for other charges. Kitchens filed a motion for a new trial, claiming, among other things, that his constitutional right to a speedy trial was violated.The trial court denied Kitchens's motion for a new trial, rejecting his speedy-trial claim. Kitchens appealed, arguing that the trial court made a clearly erroneous finding about a material fact and misapplied the law in several significant ways. The trial court found that the delay was due to the complexity of the case and the State's ongoing investigation, and it did not weigh this factor heavily against the State. The court also found that Kitchens never invoked his right to a speedy trial, which was a clearly erroneous finding since Kitchens had filed a constitutional speedy trial demand in August 2014.The Supreme Court of Georgia reviewed the case and found that the trial court made several errors in its analysis. The trial court failed to calculate the length of the delay correctly, conflated the analyses of presumptive prejudice and the length of the delay, and did not consider whether the delay was uncommonly long. The Supreme Court vacated the trial court's order denying Kitchens's motion for a new trial and remanded the case for the trial court to properly address the speedy-trial claim, considering the correct facts and legal analysis. View "KITCHENS v. THE STATE" on Justia Law

Gregory M. Hilton was convicted of malice murder and other crimes after he shot and killed his next-door neighbor, Tommy Allen, on January 29, 2018. Hilton was indicted on charges of malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. After a series of competency evaluations, Hilton was found competent to stand trial. During the trial, evidence showed that Hilton shot Allen as he was getting into his car. Hilton confessed to the murder and explained that he was in a dire financial situation and felt hopeless. He claimed that Allen had violated him, although he could not specify how.The Chatham County trial court found Hilton guilty on all counts, sentencing him to life in prison for malice murder and an additional five years for the firearm offense. Hilton's motion for a new trial was denied. He appealed, arguing that the trial court erred by not instructing the jury on voluntary manslaughter.The Supreme Court of Georgia reviewed the case. Hilton contended that his statements about feeling threatened by Allen warranted a voluntary manslaughter instruction. The court was skeptical that Hilton's vague statements constituted sufficient evidence of provocation. However, even if the trial court erred in not giving the instruction, the Supreme Court concluded that any error was harmless. The evidence strongly indicated that Hilton acted with malice aforethought due to his financial desperation, and the jury would likely have rejected a voluntary manslaughter claim. Therefore, the Supreme Court of Georgia affirmed Hilton's convictions. View "HILTON v. THE STATE" on Justia Law

Yaquan Chapman and Jordan Watson were convicted for the shooting death of William Trawick and the assault of Aubrey Stansill and Griffin Cleveland. On February 16, 2021, Chapman, Watson, Calvin Rozier, and Carey Williams planned to rob Trawick during a marijuana purchase. They recruited Christian Miles to drive them to Trawick’s home. Watson carried an AR-15, while Rozier and Chapman had handguns. After spending time inside Trawick’s home, Rozier signaled the start of the robbery. Williams retrieved Watson from the car, and the group began shooting, resulting in Trawick’s death and injuries to Stansill and Cleveland. The group fled but returned to retrieve personal items, leading to more gunfire. Chapman was injured, and the group eventually dispersed after seeking medical help for Chapman.A Butts County grand jury indicted Chapman, Watson, Rozier, and Williams. Williams’s case was severed, and he testified for the State. Following a jury trial, Chapman and Watson were found guilty on all counts and sentenced to life in prison without parole for malice murder, plus additional years for aggravated assault. Both filed motions for a new trial, which were denied by the trial court.The Supreme Court of Georgia reviewed the case. Chapman argued trial errors and ineffective assistance of counsel, while Watson contended insufficient evidence and ineffective assistance of counsel. The court found sufficient evidence to support the convictions, noting the testimonies and physical evidence linking both defendants to the crimes. The court also held that the trial court did not abuse its discretion in its rulings and that the defendants failed to demonstrate prejudice from their counsel’s actions. Consequently, the Supreme Court of Georgia affirmed the convictions and sentences of both Chapman and Watson. View "CHAPMAN v. THE STATE" on Justia Law

Xavier Adams, Jr. was convicted of felony murder and other crimes related to the shooting death of Sean Peterson. The incident occurred on September 5, 2017, when Peterson, Adams, and Adams's then-wife, Destinee Pannell, were roommates. An argument over rent escalated, leading to both men retrieving firearms. During a struggle, Peterson was shot and killed. Adams attempted to cover up the incident by creating an alibi and preventing Pannell from contacting the police. Adams was indicted on multiple charges, including malice murder and felony murder, and was found guilty by a jury in June 2019.The trial court sentenced Adams to life in prison without parole for felony murder predicated on possession of a firearm by a convicted felon. Adams filed a motion for a new trial, which was denied after an evidentiary hearing. He then appealed to the Supreme Court of Georgia, arguing several points, including the trial court's failure to vacate his felony murder conviction under the modified merger rule, mutually exclusive verdicts, improper comments on evidence, and errors in jury instructions.The Supreme Court of Georgia affirmed the trial court's decision. The court held that the modified merger rule did not apply because Adams's possession of the firearm was independent of the killing. The court also found that the verdicts were not mutually exclusive, as felony murder predicated on possession of a firearm does not require intent to kill. Additionally, the court concluded that the trial court did not improperly comment on the evidence, did not commit plain error in its jury instructions, and that Adams had affirmatively waived any claim of error regarding the trial court's response to a jury note. View "ADAMS v. THE STATE" on Justia Law

Steven Alford Jacobs was convicted of malice murder and other crimes related to the shooting death of Curtis Pitts. The incident occurred on September 21, 2018, and Jacobs was indicted on multiple charges, including malice murder, felony murder, aggravated assault, armed robbery, and possession of a firearm during the commission of a felony. The jury found Jacobs guilty on all counts, and he was sentenced to life in prison without the possibility of parole for malice murder, among other sentences for the additional charges.Jacobs filed a motion for a new trial, which was denied by the trial court. He appealed, arguing that his constitutional right to be present during a critical phase of the trial was violated when the jury viewed a vehicle connected to the charges without him being present. During the trial, the jury was allowed to view the van involved in the case, and Jacobs's defense objected, questioning whether the van was in the same condition as it was in 2018. The trial court allowed the viewing, and Jacobs's attorneys testified that they had discussed the right to be present with Jacobs, who chose not to attend the viewing.The Supreme Court of Georgia reviewed the case and affirmed the trial court's decision. The court held that even if Jacobs had a right to be present during the jury's viewing of the van, the evidence supported the trial court's conclusion that Jacobs waived that right. The court found that Jacobs's attorneys had informed him of his right to be present, and Jacobs had explicitly declined to attend the viewing. Therefore, the trial court's finding that Jacobs waived his right to be present was not clearly erroneous, and Jacobs was not entitled to a new trial based on his absence during the jury's viewing of the van. View "JACOBS v. THE STATE" on Justia Law

Aaron Lewis was indicted in Gwinnett County in 2021 for the felony murders of Dieterick Stephen Duncker and Alexandria Thompson, along with other related crimes. The indictment alleged that Lewis sold and distributed fentanyl-laced heroin to Duncker and Thompson, causing their deaths in Gwinnett County. Lewis filed a motion to dismiss the felony-murder counts, arguing that venue was improper in Gwinnett County since the sales occurred in DeKalb County.The trial court denied Lewis's amended motion to dismiss, reasoning that the ingestion of the narcotics and the resulting deaths in Gwinnett County made venue proper there. The court granted a certificate of immediate review, and Lewis's interlocutory application to review the trial court's ruling on venue was accepted.The Supreme Court of Georgia reviewed the case and vacated the trial court's order denying Lewis's amended motion to dismiss. The Supreme Court found that the trial court had improperly relied on the case Eubanks v. State, which dealt with the sufficiency of evidence for a felony murder conviction, not venue. The Supreme Court clarified that the relevant question for venue is where the cause of death was inflicted, as per OCGA § 17-2-2 (c). The case was remanded for further proceedings consistent with this opinion. View "Lewis v. State" on Justia Law

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