Justia Georgia Supreme Court Opinion Summaries

The case concerns the fatal shooting of Samantha Bozeman by Maxwell Lartery on February 5, 2024, at Bozeman’s home in Fulton County, Georgia. Lartery, Bozeman’s boyfriend, was involved in a heated argument with her, which was partially captured on video by Bozeman’s Ring surveillance camera. After Bozeman threw water at Lartery and locked him out, Lartery retrieved a handgun from his fanny pack and fired four shots through the front door, subsequently exclaiming, “That’s what! You’re dead.” Bozeman was later found dead from gunshot wounds. Witnesses and video evidence identified Lartery as the shooter. Lartery denied responsibility, claimed he was being framed, and offered alternative theories, but ultimately admitted to firing his gun after being confronted with video evidence.The Superior Court of Fulton County presided over the trial, where a jury found Lartery guilty of malice murder and related charges. The court sentenced him to life imprisonment with the possibility of parole and imposed additional consecutive sentences. Lartery’s motions for a new trial were denied without a hearing, and he appealed his conviction.The Supreme Court of Georgia reviewed the case, considering Lartery’s claims that the trial court erred by refusing to instruct the jury on voluntary manslaughter and by admitting expert testimony on domestic violence. The court held that there was insufficient evidence of serious provocation to warrant a voluntary manslaughter charge, as the facts did not meet the objective standard required by Georgia law. Regarding the expert testimony, the court found that even if its admission was erroneous, any error was harmless given the overwhelming evidence of Lartery’s guilt. Accordingly, the Supreme Court of Georgia affirmed the judgment of conviction. View "LARTERY v. THE STATE" on Justia Law

The appellant was convicted of felony murder and other offenses after leading law enforcement officers on a high-speed chase that resulted in a fatal collision. On April 5, 2024, police attempted to stop the appellant’s vehicle for a broken brake light, but he fled, leading officers onto Interstate 285. The pursuit ended when the appellant exited the highway, ran a red light at high speed, and crashed into another vehicle, killing the driver, Tamara Taylor. Evidence showed the appellant was driving recklessly and accelerating as he entered the intersection. He was on felony probation at the time, and over an ounce of marijuana was found in his vehicle.The case was tried in the Superior Court of Fulton County. At trial in April 2025, the jury acquitted the appellant of charges related to a prior pursuit on April 3, 2024, but convicted him of the remaining counts. The trial court sentenced him to life for felony murder and ten years for possession of marijuana, with several counts merged for sentencing. The appellant filed a motion for new trial, which was denied, and subsequently appealed.The Supreme Court of Georgia reviewed the case. The Court held that excluding the Georgia State Patrol’s written pursuit policy from evidence did not constitute plain error, as the appellant did not demonstrate that its admission would have affected the trial’s outcome; the appellant was permitted to question the officer in detail about the policy. The Court also found no plain error in the jury instructions regarding causation and intervening cause, as the appellant had agreed to the instructions at trial. The admission of evidence regarding felony probation was upheld as probative of motive and not unduly prejudicial. Sentencing and merger issues were found either proper or beneficial to the appellant. The Court concluded no cumulative error deprived the appellant of a fair trial and affirmed the judgment. View "HICKS v. THE STATE" on Justia Law

The dispute concerned ownership of a strip of land at the boundary between two neighboring properties. The petitioner initiated litigation to resolve title to this land, and the respondents answered and asserted counterclaims. With both parties’ consent, a special master reviewed the title issues. The trial court adopted part of the special master’s recommendation, rejected the petitioner’s claims, and vested title in the respondents. Before the respondents’ counterclaims could be tried, they voluntarily dismissed those claims. Subsequently, the petitioner filed a notice of appeal challenging the trial court’s order on title.The Court of Appeals of Georgia reviewed the case and determined that the petitioner’s appeal was untimely. The court reasoned that the notice of appeal was filed more than 30 days after the entry of the trial court’s order and held that the voluntary dismissal of the counterclaims did not render the earlier order appealable as a final judgment. The majority relied on Dykes v. Atlanta Paving & Concrete Construction, which held that the date of entry of the original order determines its finality for appeal purposes, not subsequent dismissals of remaining claims. A dissent argued that an order could become final due to subsequent events, such as dismissal of remaining claims.The Supreme Court of Georgia granted certiorari and concluded that the appeal was timely. The Court held that when all remaining claims were dismissed, the prior order became a final judgment, triggering the 30-day period to file a notice of appeal. The Court overruled Dykes and similar precedents, clarifying that a judgment can become final due to subsequent events and not solely upon original entry. The Supreme Court vacated the Court of Appeals’ dismissal and remanded the case for consideration of the merits. View "NEELY v. PARSELL" on Justia Law

A man was shot and killed outside his home in Fulton County, Georgia. The victim, Sutton Tennyson, was conversing with a carpenter, Carl Price, when Michael Shareef Williams arrived in a dark-colored BMW. After a heated exchange about money, Williams followed Tennyson to his garage and shot him multiple times. Price witnessed the shooting and later described the attacker to police, though he was unable to identify Williams from photos immediately after the incident. Another neighbor, Frank Pickens, identified Williams as the man fleeing the scene. Evidence included surveillance footage, license plate reader data linking the BMW to Williams, and text messages between Williams and Tennyson discussing money.Williams was indicted in the Superior Court of Fulton County for murder and several related charges. In March 2022, a jury found him guilty on all counts. The trial court sentenced Williams to life with the possibility of parole on the malice murder count and imposed additional consecutive sentences for other firearm-related offenses. Several counts were merged or vacated by operation of law. Williams filed a timely motion for new trial, which was denied after a hearing. The trial court later vacated its previous denial and entered a new order, again denying the motion. Williams appealed, and the case was transmitted to the Supreme Court of Georgia.The Supreme Court of Georgia affirmed Williams’s convictions. The Court held that the trial court did not plainly err by failing to give a limiting instruction when evidence of Williams’s prior convictions was admitted, as Williams did not request one at the time. It also found no constitutional ineffectiveness by Williams’s trial counsel, whether for failing to stipulate to Williams’s felon status, failing to seek a limiting instruction, or failing to object to hearsay testimony. Claims of cumulative error were rejected, as only one instance of deficient performance was assumed without deciding. Judgment was affirmed. View "WILLIAMS v. THE STATE" on Justia Law

The defendant was convicted of malice murder and robbery following the death of a woman with whom he had a deteriorating relationship. Evidence at trial showed that he had threatened her life in the days leading up to the incident, and witnesses testified to his hostile intent. On the day of the crime, the victim left a friend’s house to check her mail and did not return. The defendant’s brother testified that the defendant went to their shared apartment with the intention of confronting the victim, gagged and bound her, and transported her in her vehicle. Physical evidence at the scene, including matching boot prints and DNA, corroborated the brother’s account. The defendant’s girlfriend and other witnesses provided additional evidence regarding his whereabouts. The victim’s body and belongings were found along a highway, and the medical examiner confirmed death by blunt force trauma. The defendant testified in his own defense, providing an alternate account of his movements.The Superior Court of Burke County presided over the trial, during which a jury found the defendant guilty of both charges. After sentencing, the defendant filed several post-trial motions, including motions for new trial. There was an extended delay in post-conviction proceedings, with issues regarding missing transcripts and unavailable evidence. Ultimately, the trial court denied the defendant’s motions for new trial, finding no prejudice from the delay and rejecting claims of ineffective assistance of counsel.The Supreme Court of Georgia reviewed the case on appeal. The court held that the evidence was sufficient to support both convictions under constitutional and statutory standards. The court further held that the defendant’s claims of ineffective assistance of counsel failed because there was no objectively unreasonable performance or resulting prejudice. The court also found no due process violation from the prosecution’s conduct or from the post-conviction delay, as no actual prejudice was demonstrated. The judgment was affirmed. View "JOHNSON v. THE STATE" on Justia Law

In this case, the defendant was charged with malice murder and related offenses following the August 2016 shooting death of a woman who was killed while driving away from a friend’s house in Fulton County, Georgia. The investigation linked the defendant and several others to the crime through a combination of witness testimony, forensic ballistics, and cell phone location data. A key witness, who was an accomplice and had entered a plea to a reduced charge, testified that the group, including the defendant, planned and executed a retaliatory shooting in the area where the victim was killed. The defendant contested his involvement, claiming that he was not present during the shooting and that his cell phone, which was tracked to the scene, was not in his possession at the relevant time.The Superior Court of Fulton County initially conducted a joint trial for the defendant and two co-defendants. The jury convicted the co-defendants but was unable to reach a verdict as to the defendant, resulting in a mistrial. The defendant was retried separately and found guilty on all counts. He subsequently filed a motion for new trial, which was denied after an evidentiary hearing. The defendant then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia affirmed the convictions. It held that the evidence, viewed in the light most favorable to the verdict, was constitutionally sufficient to support the convictions, and that the accomplice’s testimony was adequately corroborated by independent evidence, including physical evidence and cell phone data. The Court also held that the defendant, by remaining silent and failing to object when the trial court declared a mistrial in the first trial, had consented to the mistrial, and thus could not later invoke double jeopardy principles to bar retrial. Accordingly, the judgment was affirmed. View "ASH v. THE STATE" on Justia Law

The case concerns the shooting death of Keenan Leonard on January 1, 2021. Investigators traced a maroon SUV seen fleeing the scene to the mother of Camron Chase Downing. Evidence linked Downing to a .357 Magnum revolver, which was ultimately recovered after police questioned his brother, Cole, who had moved the gun to a friend's property. Downing was indicted for malice murder and related charges. At trial, the prosecution relied on forensic evidence connecting the revolver to the shooting and Downing’s prior possession of the weapon. Downing was convicted on all counts and sentenced to life without parole.After his conviction in the Superior Court of Troup County, Downing, represented by new counsel, filed a motion for a new trial. He argued that the murder weapon should have been suppressed as the "fruit of the poisonous tree," since it was discovered based on his unwarned, custodial statement to police, allegedly obtained in violation of Miranda v. Arizona, 384 U.S. 436 (1966). Downing also claimed his trial counsel was ineffective for failing to introduce key bodycam footage showing how police used his statement to pressure Cole into revealing the gun's location. The trial court agreed, finding the gun inadmissible and that counsel was ineffective.On appeal, the Supreme Court of Georgia examined whether the trial court erred in granting a new trial. The Supreme Court held that physical evidence derived from an unwarned statement is only suppressible if the statement was involuntary, not merely because Miranda warnings were not given. The trial court had not made a finding as to whether Downing’s statement was voluntary. Therefore, the Supreme Court of Georgia vacated the trial court’s order granting a new trial and remanded the case for a determination of voluntariness under the correct legal standards. View "THE STATE v. DOWNING" on Justia Law

The case concerns a fatal stabbing that occurred in April 2019, in which the defendant, who had been living with the victim’s family and was a longtime friend, killed the victim after the two smoked what was later determined to be synthetic marijuana. Eyewitnesses, including children present in the home, observed the defendant stabbing the victim and fleeing the scene, while evidence indicated a violent and chaotic struggle. Law enforcement apprehended the defendant not far from the scene, where he admitted to having stabbed his friend. At trial, the defense asserted an insanity defense, arguing that the defendant could not distinguish right from wrong due to mental illness, seizure activity, and the effects of synthetic marijuana.A DeKalb County grand jury indicted the defendant for malice murder, felony murder, aggravated assault, and possession of a knife during the commission of a felony. Following a jury trial in the Superior Court of DeKalb County, the defendant was found guilty but mentally ill on all counts. He was sentenced to life without parole for malice murder, with a consecutive five-year sentence for the weapons charge. The felony murder conviction was vacated by operation of law, and the aggravated assault conviction merged into the malice murder conviction. After the trial court denied his motion for a new trial, the defendant appealed, arguing that the court’s decision to limit the testimony of his expert witness on the insanity defense was erroneous.The Supreme Court of Georgia reviewed whether the trial court erred in granting the State’s motion in limine to restrict the defense expert’s testimony regarding the defendant’s motive, plan, or efforts to conceal evidence. The Court held that, even assuming error, any limitation was harmless because the expert ultimately testified to the substance of the prohibited topics using different language. The Court thus affirmed the defendant’s convictions. View "REYNOLDS v. THE STATE" on Justia Law

In this case, the defendant was arrested after striking an elderly pedestrian with her car, fleeing the scene, and later being found by police in an intoxicated state with a suspended license. The victim suffered serious injuries and died from a stroke about ten days later. The defendant, who had a significant history of DUI and traffic offenses, was indicted on multiple counts, including homicide by vehicle predicated on DUI, reckless driving, and hit-and-run. She ultimately entered a non-negotiated guilty plea to most charges and received a 15-year prison sentence for the most serious count.Following her conviction, the defendant filed a petition for habeas corpus in the Superior Court of Hart County. She argued that her court-appointed plea counsel was constitutionally ineffective by not informing her of her right to withdraw her guilty plea within the term of court and by failing to provide her with copies of discovery materials that she claimed could have supported defenses at trial. The habeas court held an evidentiary hearing and granted relief, finding that counsel’s omissions deprived her of effective assistance and vacating her convictions and sentences.The Supreme Court of Georgia reviewed the habeas court’s decision. It held that, even assuming plea counsel’s performance was deficient, the defendant failed to show prejudice as required under Strickland v. Washington. The Court found that she was aware of the circumstances discussed in the withheld discovery materials through discussions at the plea hearing and that there was no evidence she would have insisted on going to trial but for counsel’s alleged errors. The Supreme Court of Georgia reversed the habeas court’s grant of relief. View "ORSBORN v. LONG" on Justia Law

The case concerns a man who was convicted for the shooting death of his wife. The critical events took place over the course of two days in October 2020. The defendant, believing his wife was involved with her ex-boyfriend, confronted her after seeing the ex-boyfriend in their home during a video call. After expressing anger to an acquaintance and returning home, he later shot and killed his wife while a child was present. The defendant made multiple confessions to others immediately after the shooting and then fled, evading law enforcement for several days before being arrested with the murder weapon in his possession.The Superior Court of Polk County presided over the trial, where a jury convicted the defendant of malice murder and several related offenses. The court sentenced him to life in prison without parole for malice murder and additional concurrent and consecutive sentences for the other convictions. The court vacated one felony murder count by operation of law and merged the aggravated assault count for sentencing. The defendant timely moved for a new trial, which was denied, and he then appealed.The Supreme Court of Georgia reviewed the case. The defendant argued that his trial counsel was constitutionally ineffective for not objecting to law enforcement testimony regarding his emotional state during a custodial interview, and for failing to investigate a theory that his wife had been poisoning him. The court held that counsel’s actions were not objectively unreasonable and that the defendant did not demonstrate prejudice, as he failed to show what further investigation would have revealed. The Supreme Court of Georgia affirmed the convictions, finding no ineffective assistance of counsel. View "BLACKMON v. THE STATE" on Justia Law