Justia Georgia Supreme Court Opinion Summaries

Appellant Elkin King sued Appellee Forrest King, Jr., his former stepfather, in federal district court, alleging that Forrest had concealed, misused, and converted the proceeds of a wrongful death settlement that had been placed in an account for Appellant’s benefit when Appellant was a minor, and Forrest was the custodian. Appellant further alleged that Forrest’s actions had allowed Appellant’s mother, Peggy Fulford, to spend the funds remaining in the account after Appellant turned 18 years old. The district court granted summary judgment in favor of Forrest. The United States Court of Appeals for the Eleventh Circuit affirmed summary judgment on the misuse claim and held that Appellant had forfeited his conversion claim. But as to the concealment claim, the Eleventh Circuit certified three questions to the Georgia Supreme Court, seeking clarification of the parameters of Georgia’s duty to disclose in a confidential relationship. The Supreme Court responded to the Eleventh Circuit’s certified questions: when a confidential relationship is also a fiduciary relationship, the fiduciary’s fraudulent breach of the duty to disclose can give rise to a breach-of-fiduciary-duty tort claim if that breach violates a fiduciary’s duty to act with the utmost good faith. "But whether a fiduciary has failed to act with the utmost good faith in a particular circumstance is a question of fact, not law." Accordingly, the Supreme Court answered the Eleventh Circuit’s first question and declined to answer the other two questions. View "King v. King" on Justia Law

In 2007, Jeremy Moody was charged with the rape and murder of 13-year-old Chrisondra Kimble and the murder of Kimble’s 15-year-old cousin, Delarlonva Mattox, Jr., and other related offenses. Shortly after Moody’s jury trial began in April 2013, Moody pleaded guilty to two counts each of malice murder, felony murder predicated on aggravated assault, aggravated assault, aggravated assault with intent to rob, and kidnapping with bodily injury, as well as to one count of rape. At the conclusion of the sentencing phase, a jury found the existence of multiple statutory aggravating circumstances as to each murder and recommended a sentence of death for each murder, and the trial court sentenced Moody accordingly. On appeal, Moody raised thirteen claims of error, each of which the Georgia Supreme Court rejected, affirming the convictions and sentence. View "Moody v. Georgia" on Justia Law

A habeas court granted relief to Jonathon Medina on the grounds that his guilty plea was involuntary and trial counsel was ineffective. Timothy Ward, the Commissioner of the Georgia Department of Corrections, appealed the habeas court’s order, challenging each of those grounds. Because the Georgia Supreme Court concluded the habeas court did not err in granting relief to Medina on his involuntary-plea claim, and affirmed the habeas court’s decision on that ground without addressing that court’s rulings on Medina’s ineffective assistance claims. View "Ward v. Medina" on Justia Law

Appellant Dwight Blalock, Jr., was convicted of malice murder and other crimes in connection with the 2014 fatal shooting of Carlos Wright and the aggravated assault of Bryan Morrow. On appeal, Blalock contended: (1) the trial court abused its discretion and denied Blalock due process by refusing to grant his motion for continuance; (2) Blalock’s trial counsel rendered ineffective assistance by failing to argue that the discovery statute, OCGA § 17-16-4, was unconstitutional as applied in this case; and (3) the trial court erred in permitting a State’s witness to comment on Blalock’s silence. Finding no reversible error, the Georgia Supreme Court affirmed Blalock’s convictions. View "Blalock v. Georgia" on Justia Law

In 2017, Erasmus Chandler was found guilty by jury of aggravated child molestation and two counts of child molestation. In 2019, the Court of Appeals affirmed his convictions in an unpublished opinion. Chandler later filed a pro se petition for habeas corpus, which the habeas court granted in 2022 on the ground that Chandler’s appellate counsel provided ineffective assistance at the motion for new trial stage and on appeal, including by failing to raise and prove claims of ineffective assistance of trial counsel. Warden Aimee Smith appealed, arguing that the habeas court erred in admitting an exhibit at the habeas hearing and in determining that Chandler’s appellate counsel provided ineffective assistance. The Georgia Supreme Court found the the warden did not object to the admission of the challenged exhibit for the limited purpose for which it was admitted, and on appeal the warden has not shown plain error in its admission. Moreover, the habeas court properly determined that Chandler’s appellate counsel provided ineffective assistance at the motion for new trial stage and on appeal by failing to raise and prove a claim of ineffective assistance of trial counsel for failing to impeach the alleged victim’s testimony at trial with evidence that she had made prior inconsistent statements about the alleged abuse. Accordingly, the Supreme Court affirmed the habeas court’s grant of relief on this basis. View "Smith v. Chandler" on Justia Law

Brandon Williams appealed his convictions for malice murder and possession of a firearm during the commission of a felony in connection with the shooting death of Corey Coleman. Williams contended the trial court erred: (1) when it did not allow him to show his left arm during the cross-examination of a detective; (2) when it allowed testimony about a deceased person’s out-of-court identification of Williams; (3) when it failed to charge the jury on self-defense; and (4) when it allowed introduction of Coleman’s statements to his mother. Williams also contended he received ineffective assistance of trial counsel. Finally, Williams argued the cumulative errors created sufficient prejudice that he must receive a new trial. Because Williams failed to show reversible error, the Georgia Supreme Court affirmed. View "Williams v. Georgia" on Justia Law

Appellants Michael Ward and Frederick Dewberry were convicted of malice murder and felony murder in connection with the stabbing death of Antonio Wiley and aggravated assault in connection with the stabbing of Wydreicus Denison. Ward contended: (1) the evidence was not sufficient to support his convictions; and (2) the trial court erred in denying his motion for a new trial. In his appeal, Dewberry contended the trial court erred by: (1) denying his motion for directed verdict of acquittal on the murder and aggravated assault charges; (2) allowing a “heavy police presence” in the courtroom in violation of his right to a fair trial; (3) leaving a defense witness in visible restraints; and (4) not declaring a mistrial after the prosecutor conferred with a witness, in violation of the rule of sequestration. Finding no reversible error in either appellant's contentions, the Georgia Supreme Court affirmed in both cases. View "Ward v. Georgia" on Justia Law

Manvel Britton was charged with murder and other offenses in connection with the fatal shooting of Eddy Leonardo. The State appealed the trial court’s grant of Britton’s motion to suppress evidence from his cell phone records obtained pursuant to a search warrant (the “Warrant”) during the police investigation into that death. The trial court found that the affidavit for the Warrant (the “Affidavit”) contained a material misrepresentation which tainted the entire document, and, with that misrepresentation excluded, the Affidavit failed to establish the requisite probable cause to issue the Warrant. The trial court further found a “discrepancy” in the Affidavit that it determined affected the validity of the Warrant. The State argued on appeal that in reaching these conclusions, the trial court did not properly apply the law and failed to give proper deference to the magistrate judge who issued the Warrant. To this the Georgia Supreme Court agreed, reversed and remanded for further proceedings. View "Georgia v. Britton" on Justia Law

Lorenzo Harris was indicted for malice murder and other offenses arising from the shooting of Larry Jones. The State appealed the trial court’s pretrial rulings, which were not reduced to writing, granting Harris’s motion in limine to exclude evidence of two prior incidents and his motion to suppress identification evidence. In the absence of a written order from the trial court regarding the appealed rulings, the Georgia Supreme Court directed the parties to brief the issue of the Supreme Court’s jurisdiction. Upon review, the Court concluded it had jurisdiction over these appeals, vacated the trial court’s rulings, and remanded for further proceedings. View "Georgia v. Harris" on Justia Law

Bryan Jones was convicted of felony murder and other offenses in connection with a shooting that killed Dorian Drewery and injured Joshua Childs. Jones appealed, arguing: (1) the trial court erred in giving a jury instruction on other-acts evidence under OCGA § 24-4-404 (b) when no such evidence was admitted at trial; and (2) trial counsel rendered constitutionally ineffective assistance in (a) agreeing to a stipulation that prejudiced Jones’s defense and (b) failing to request a jury instruction on voluntary manslaughter. The Georgia Supreme Court concluded the trial court’s error in giving the other-acts jury instruction was harmless: among other things, the court omitted that oral instruction from the written instructions sent back with the jury; it properly instructed that other acts could be considered only if it was more likely than not that Jones had committed them, and because there was no evidence of such other acts, the jury could not have made that finding; and in any event, the instruction had little relevance to the central question of whether Jones’s use of deadly force was justified under the circumstances. As for the ineffective-assistance claims, the Supreme Court found the record showed that trial counsel’s decision to agree to the stipulation was the product of a reasonable strategic effort to prevent the State from offering potentially “devastating” rebuttal evidence. Similarly, counsel’s decision not to request a jury instruction on voluntary manslaughter was reasonable given Jones’s desire to present an “all or nothing” justification defense and the fact that the evidence supporting voluntary manslaughter was thin. So Jones failed to establish trial error or ineffective assistance, and the Supreme Court therefore affirmed his convictions and sentences. View "Jones v. Georgia" on Justia Law