Justia Georgia Supreme Court Opinion Summaries

The case involves family members of drug abusers suing wholesale distributors of prescription medications. The plaintiffs alleged that the distributors violated state and federal laws by failing to report suspicious orders of controlled substances, which led to the drug abusers' addictions and subsequent harm to the plaintiffs. The plaintiffs sought damages under the Georgia Drug Dealer Liability Act (DDLA) and other legal theories.The case was initially tried in a lower court, where a jury returned a verdict in favor of the distributors. The plaintiffs then moved for a new trial, arguing that a juror was dishonest during the selection process and introduced extraneous prejudicial information during deliberations. The trial court denied the motion for a new trial, leading to the current appeal.The Supreme Court of Georgia reviewed the case. The plaintiffs argued that the trial court erred in denying their motion for a new trial and in refusing to instruct the jury on willful blindness. The distributors cross-appealed, arguing that if the judgment was vacated, the DDLA should be declared unconstitutional. The Supreme Court of Georgia affirmed the trial court's decision, finding no abuse of discretion in denying the motion for a new trial. The court held that the trial court was authorized to credit the juror's testimony over the plaintiffs' evidence and that the jury was properly instructed on the relevant legal issues. The cross-appeal was dismissed as moot. View "CARDINAL HEALTH INC. v. POPPELL" on Justia Law

Fifteen-year-old Bjorn Harris was arrested on April 30, 2023, for murder and other charges related to the shooting death of Jaylan Major. He was detained at the Regional Metro Youth Detention Facility. On May 5, 2023, the Superior Court of Fulton County found probable cause for the charges, appointed counsel for Harris, and denied bond. Harris was indicted on July 28, 2023, for voluntary manslaughter, aggravated assault with a deadly weapon, and possession of a firearm during the commission of a felony. On November 16, 2023, he was reindicted for murder, felony murder, and additional charges. The initial indictment was nolle prossed on November 21, 2023.Harris filed a motion on December 1, 2023, to transfer his case to juvenile court, arguing that the State failed to indict him within 180 days as required by OCGA § 17-7-50.1. The Superior Court held a hearing on December 7, 2023, and granted the motion on December 11, 2023, relying on the Court of Appeals' decision in State v. Armendariz. The court concluded that the reindictment outside the 180-day period necessitated the transfer to juvenile court.The Supreme Court of Georgia reviewed the case and reversed the Superior Court's decision. The Supreme Court held that OCGA § 17-7-50.1 requires a grand jury to return a true bill of indictment within 180 days of detention, which was met with the July 2023 indictment. The statute does not prohibit reindictment outside the 180-day period. Therefore, the Superior Court retained jurisdiction, and the transfer to juvenile court was not authorized. The Supreme Court clarified that the timely return of a true bill on any charge within the superior court's jurisdiction suffices to retain jurisdiction, regardless of subsequent reindictments. View "THE STATE v. HARRIS" on Justia Law

In April 2015, Donte Wyatt was involved in a series of violent incidents, including the strangulation death of Catherine Montoya. Wyatt was married to Heather Duffy, who had moved out with their children. On April 13, 2015, Wyatt lured Duffy to a diner under the pretense of returning her car keys. During the meeting, Wyatt attacked Duffy, stabbing her multiple times and threatening to kill her. Duffy managed to escape, and Wyatt fled the scene in a rental truck. Later that day, Wyatt was found outside Montoya’s house, where he had murdered her. Montoya’s body was discovered with multiple injuries and evidence of sexual assault.Wyatt was indicted by a DeKalb County grand jury on multiple charges, including malice murder, aggravated assault, and rape. In October 2016, a jury found him guilty on all counts. He was sentenced to multiple life sentences, some without the possibility of parole. Wyatt filed a motion for a new trial, which was denied by the trial court in September 2023. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Wyatt’s appeal, which argued that the trial court erred in admitting evidence of his attack on Duffy, claiming it was unfairly prejudicial. The court held that the evidence was highly probative in rebutting Wyatt’s insanity defense, as it demonstrated his awareness of the wrongfulness of his actions and his ability to act with deliberation. The court found that the probative value of the evidence was not substantially outweighed by the danger of unfair prejudice. Consequently, the court affirmed the trial court’s decision to admit the evidence and upheld Wyatt’s convictions. View "WYATT v. THE STATE" on Justia Law

John Doe, a patient at Ridgeview Institute – Monroe, sued the facility's owners, operators, and CEO after a former employee, Rhonda Rithmire, disclosed patient information without authorization. Doe sought to represent a class of affected patients, alleging multiple claims including breach of contract and negligence. The trial court denied Doe's motion for class certification, finding that he failed to meet the commonality and typicality requirements under OCGA § 9-11-23 (a). Specifically, the court noted that Doe's disclosed information did not include diagnosis or treatment details, unlike other patients whose more sensitive information was revealed.Doe appealed to the Court of Appeals of Georgia, which reversed the trial court's decision. The appellate court found that Doe's claims and those of the putative class arose from the same events and were based on the same legal theories, thus satisfying the typicality requirement. One judge dissented, disagreeing with the majority's interpretation of the typicality and commonality requirements.The Supreme Court of Georgia reviewed the case to determine if the trial court abused its discretion in denying class certification. The Supreme Court concluded that the trial court acted within its discretion in finding a lack of typicality. The court noted that the differences in the type of information disclosed among class members could lead to different legal theories and defenses, making Doe's claims not typical of the class. As a result, the Supreme Court reversed the Court of Appeals' decision, upholding the trial court's denial of class certification. The court did not address the commonality issue, as the lack of typicality alone was sufficient to deny class certification. View "VEST MONROE, LLC v. DOE" on Justia Law

In 2018, North American Senior Benefits, LLC (NASB) entered into employment contracts with Ryan and Alisha Wimmer, which included a restrictive covenant prohibiting them from recruiting NASB employees for two years post-termination. In 2021, after the Wimmers left NASB and allegedly started a competing business, NASB sued to enforce the covenant. The Wimmers argued that the covenant was unenforceable due to the lack of an express geographic term.The Statewide Business Court agreed with the Wimmers and granted their motion for judgment on the pleadings, finding the covenant unenforceable without an express geographic term. The Court of Appeals affirmed this decision, relying on its prior ruling in CarpetCare Multiservices v. Carle, which held that a restrictive covenant must include an express geographic term to comply with OCGA § 13-8-53 (a). One judge dissented, arguing that the GRCA does not require an express geographic term for non-recruitment provisions.The Supreme Court of Georgia reviewed the case and concluded that the Court of Appeals erred. The Supreme Court held that OCGA § 13-8-53 (a) does not mandate an express geographic term for a restrictive covenant to be enforceable. Instead, the statute requires that the restrictions be reasonable in time, geographic area, and scope of prohibited activities. The Court emphasized that the reasonableness of a covenant's geographic scope should be assessed based on the totality of the circumstances, not solely on the presence of an express geographic term.The Supreme Court reversed the judgment of the Court of Appeals and remanded the case for further proceedings to determine the reasonableness of the non-recruitment provision under the GRCA. View "NORTH AMERICAN SENIOR BENEFITS, LLC v. WIMMER" on Justia Law

A group of property owners sued Columbia County over stormwater drainage issues that caused damage to their property. The property, purchased in 1996, contained a metal pipe used in the County's stormwater system. Over the years, heavy rains caused the pipe to fail multiple times, leading to significant property damage. The property owners sent a notice to the County in October 2013, outlining their claims, but the County declined to make repairs. The property owners then filed a lawsuit in March 2014, seeking damages and an injunction to prevent further damage.The trial court found in favor of the property owners, ruling that the County maintained a nuisance that amounted to a taking without just compensation. The court awarded damages and issued a permanent injunction against the County. The County appealed to the Court of Appeals, which affirmed some parts of the trial court's decision and vacated others. The Court of Appeals vacated the damages award for harms incurred after the October 2013 notice and reversed the award of attorneys' fees. However, it upheld the injunction against the County.The Supreme Court of Georgia reviewed the case and vacated the Court of Appeals' decision to uphold the injunction, ruling that it exceeded the bounds of the Georgia Constitution's limited waiver of sovereign immunity. The Court directed the Court of Appeals to remand the case to the trial court to consider a new injunction within the constitutional limits. The Supreme Court also concluded that it should not have granted certiorari on the issue of damages for harms incurred after the October 2013 notice, as the Court of Appeals' ruling was specific to the facts of this case and did not establish a general rule of law. The petition for certiorari on this issue was therefore denied. View "Satcher v. Columbia County" on Justia Law

Ryan Milliron submitted an Open Records Act request to Manos Antonakakis, a professor at Georgia Tech, seeking records related to Antonakakis’s services to Georgia Tech as a private contractor. Milliron also sent a similar request to Georgia Tech. Antonakakis did not respond individually, but Georgia Tech provided some documents. Unsatisfied, Milliron sued Antonakakis, alleging he held additional public records in his capacity as a private contractor. Milliron claimed Antonakakis’s companies, formed to receive DARPA funding for Georgia Tech, maintained relevant records.The trial court dismissed Milliron’s complaint, ruling that only agencies, not individual employees or private contractors, are obligated to produce public records under the Open Records Act. The court also found that Milliron’s request to Antonakakis was improper because Georgia Tech had a designated open records officer. The Court of Appeals affirmed the trial court’s decision, agreeing that Milliron’s request was not properly submitted to the designated officer.The Supreme Court of Georgia reviewed the case and concluded that the Open Records Act applies to records held by private contractors performing services for public agencies. The Court held that requests for such records can be made directly to the custodian of the records, including private contractors, even if the agency has a designated open records officer. The Court reversed the Court of Appeals’ decision and remanded the case for further proceedings to determine what records Antonakakis may hold and whether they are public records under the Act. View "Milliron v. Antonakakis" on Justia Law

On November 15, 2018, Misty Michelle Garrison was involved in a traffic accident, leading to charges of DUI (less safe) (alcohol), failure to maintain lane, and improper tires. The State initially filed an accusation on May 29, 2019, and later amended it on January 12, 2021, to include additional charges. At trial, evidence included testimony from witnesses and officers, with a focus on Garrison's behavior and the results of a horizontal gaze nystagmus (HGN) test conducted by Trooper Kyle McSween.The trial court denied Garrison's motion in arrest of judgment, which argued that the accusation was filed beyond the statute of limitations. The court found that the Chief Justice’s emergency orders during the COVID-19 pandemic extended the limitations period. The jury found Garrison guilty on all counts, and she was sentenced accordingly. Garrison appealed to the Court of Appeals of Georgia, which affirmed the trial court's decision, holding that the emergency orders tolled the statute of limitations and that the HGN test evidence was admissible under the Harper standard.The Supreme Court of Georgia reviewed the case and concluded that the State was not required to allege and prove the tolling of the statute of limitations due to the emergency orders. The Court reasoned that such orders are effective as a matter of law and do not require factual proof. However, the Court found that the Court of Appeals erred in applying the Harper standard to the HGN test evidence instead of the Daubert standard, which became applicable in criminal cases as of July 1, 2022. The Supreme Court vacated the judgment and remanded the case to the trial court to determine the admissibility of the HGN test evidence under the Daubert standard. If the evidence is found inadmissible, a new trial will be necessary. View "Garrison v. State" on Justia Law

A Georgia State Patrol trooper observed Christopher James Newsom making an illegal left turn into the right lane of Georgia Highway 61 southbound. Following the traffic stop, the trooper determined that Newsom was driving under the influence of alcohol. The State charged Newsom with DUI less safe, DUI per se, and improper turn at an intersection. Newsom filed a motion to suppress, arguing that OCGA § 40-6-120 (2) (B) was unconstitutionally vague under the Due Process Clause of the Fourteenth Amendment, making the traffic stop unlawful.The trial court agreed with Newsom, ruling that OCGA § 40-6-120 (2) (B) was unconstitutionally vague when read in conjunction with OCGA § 40-6-40 (c). The court found that the statutes provided conflicting directions to drivers, making it unclear whether Newsom had to complete his turn in the left lane. Consequently, the trial court dismissed the charges against Newsom, concluding that the traffic stop lacked probable cause.The Supreme Court of Georgia reviewed the case and reversed the trial court's decision. The court held that OCGA § 40-6-120 (2) (B) is not unconstitutionally vague as applied to Newsom. The statute provides clear notice that a driver making a left turn must complete the turn in the far-left lane. The court found that the trial court erred in interpreting Georgia Highway 61 as a single roadway, which led to the incorrect application of OCGA § 40-6-40 (c). The Supreme Court of Georgia concluded that the statute's language was clear and did not conflict with other statutory provisions. The case was remanded for further proceedings consistent with this opinion. View "State v. Newsom" on Justia Law

The case involves Nathanieo Pinquez Pinkins, who was convicted of malice murder and related offenses following the shooting death of Cheryl Loving and the shooting of Desiraee Clay. Pinkins and Clay had a tumultuous relationship, and after a series of confrontations, Pinkins shot at Clay in a parking lot, injuring her. Shortly thereafter, he went to Loving's house, where he shot and killed her. Evidence included surveillance footage, forensic analysis, and Pinkins' own admissions.The Gwinnett County grand jury indicted Pinkins on nine counts, including malice murder, felony murder, aggravated assault, home invasion, possession of a firearm during the commission of a felony, and aggravated battery. The jury found him not guilty of home invasion but guilty of the other charges. The trial court sentenced him to life in prison with the possibility of parole for malice murder, along with additional consecutive sentences for other charges. Pinkins filed a motion for a new trial, which was denied by the trial court.The Supreme Court of Georgia reviewed the case and affirmed the convictions. The court found that the evidence was sufficient to support the malice murder conviction, noting that the jury could reasonably infer Pinkins' intent to kill from his actions and the circumstances of the crime. The court also held that the trial court did not abuse its discretion in denying Pinkins' motion to sever the counts related to Loving from those related to Clay, as the offenses were part of a connected series of acts. The court concluded that the jury was capable of distinguishing the evidence and applying the law to each offense, as evidenced by their verdicts. View "Pinkins v. State" on Justia Law