Justia Georgia Supreme Court Opinion Summaries

Evelyn-Natasha La Anyane was convicted of driving under the influence (DUI) of alcohol less safe and other traffic offenses. During a traffic stop, she was read the statutory implied-consent warning and consented to a blood test, which revealed a blood alcohol content above the legal limit. La Anyane argued that Georgia’s implied-consent statutory scheme is unconstitutional, claiming it coerces drivers into consenting to blood tests by falsely stating that refusal can be used against them at trial. She also contended that the trial court made evidentiary errors by not allowing her to cross-examine an expert with a study on field sobriety tests and by admitting evidence of her blood alcohol content.The trial court denied La Anyane’s motion to suppress the blood test results and admitted the evidence at trial. The jury found her guilty of all charges. La Anyane appealed, arguing that the implied-consent warning was unconstitutionally coercive and that the trial court made evidentiary errors.The Supreme Court of Georgia reviewed the case and held that the implied-consent warning was not unconstitutionally coercive. The court found that the warning did not state that consent was mandatory and that the statement about refusal being used at trial was not false. The court also determined that La Anyane’s consent to the blood test was freely and voluntarily given, making the search valid under the Fourth Amendment. Consequently, her as-applied and facial challenges to the implied-consent statutory scheme failed.Regarding the evidentiary issues, the court held that the trial court did not abuse its discretion in excluding the study on field sobriety tests due to lack of proper foundation and in admitting evidence of La Anyane’s blood alcohol content, as it was relevant to the DUI less safe charge and not unfairly prejudicial. The Supreme Court of Georgia affirmed the trial court’s judgment. View "LA ANYANE v. THE STATE" on Justia Law

James Christopher Jones was charged with murder after police identified her using cell phone location history obtained through search warrants. The warrants allowed police to get an anonymized list of devices near the victim’s home during the murder and identifying information for relevant devices. Jones moved to suppress this evidence, arguing the warrants violated the Fourth Amendment due to lack of probable cause and particularity. The trial court denied the motion, and Jones appealed.The trial court found the warrants were supported by probable cause and were sufficiently particular. The first warrant was based on evidence that the suspect used a cell phone near the victim’s home, and the second warrant, obtained after analyzing the anonymized data, identified a specific device linked to the suspect. The court concluded that the affidavits provided a fair probability that the location data and identifying information would yield evidence of the crime. The court also found the warrants were particular enough, specifying the crime, date, time, location, and a reasonable 100-meter radius.The Supreme Court of Georgia affirmed the trial court’s decision. The court held that the warrants were supported by probable cause, as the suspect was seen using a cell phone near the crime scene, and the location data was likely to help identify the suspect. The court also found the warrants met the particularity requirement, as they provided specific guidance on the information to be accessed and avoided unfettered discretion. The court rejected Jones’s arguments about overbreadth and lack of particularity, noting that the warrants were appropriately tailored to the investigation and did not authorize a general search. The judgment was affirmed. View "JONES v. THE STATE" on Justia Law

Terry Griffin was convicted of malice murder and other crimes related to the shooting death of her boyfriend, Wesley Hudson, in their shared apartment. Griffin was present at the scene and arrested immediately. During the trial, her counsel initially pursued a self-defense strategy but later shifted to arguing for a lesser charge of voluntary manslaughter after Griffin decided not to testify. The jury found Griffin guilty on all counts, including malice murder and felony murder.Griffin filed a motion for a new trial, arguing that her trial counsel violated her Sixth Amendment rights by abandoning her self-defense claim in favor of voluntary manslaughter without her consent, citing McCoy v. Louisiana. The trial court denied her motion, concluding that Griffin had not shown an "intransigent and unambiguous objection" to her counsel's strategy shift and that her counsel did not concede her guilt to the charges.The Supreme Court of Georgia reviewed the case and affirmed the lower court's decision. The court held that Griffin's claim under McCoy failed because she did not make a clear and persistent objection to her counsel's strategy, as required by McCoy. The court noted that Griffin's plea of "not guilty" and her counsel's initial self-defense argument did not amount to the type of "vociferous insistence" and "adamant objection" seen in McCoy. Therefore, the court concluded that Griffin's Sixth Amendment rights were not violated, and her conviction was upheld. View "GRIFFIN v. THE STATE" on Justia Law

Roderick Watkins was convicted of malice murder and other crimes related to the March 14, 2012, shooting death of Ashley Clark and her unborn child. Watkins and Clark were in a romantic relationship that deteriorated over time, with Clark documenting physical, verbal, and emotional abuse in her diary. Clark became pregnant in late 2011, and despite Watkins's insistence on an abortion, she decided to keep the baby. On March 13, 2012, Clark wrote in her diary that Watkins planned to cause her to have a miscarriage. The next night, Watkins shot Clark, resulting in her death and the death of her unborn child.A Fulton County grand jury indicted Watkins on multiple charges, including murder and possession of cocaine. A jury found him guilty on all counts, and the trial court sentenced him to life in prison for murder and feticide, among other sentences for related charges. Watkins moved for a new trial, which was denied by the trial court. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the case and addressed several claims by Watkins. The court found that the trial court did not abuse its discretion in admitting Clark's diary entries under Rule 807, as they bore equivalent circumstantial guarantees of trustworthiness and were material and probative. The court also found no plain error in the admission of Watkins's pre-arrest silence or failure to come forward. However, the court concluded that the admission of testimony by a Georgia Bureau of Investigation analyst, who relayed the findings of a non-testifying analyst, violated the Confrontation Clause under Smith v. Arizona. Consequently, the court reversed Watkins's convictions for possession of cocaine and possession of a firearm during the commission of a felony predicated on possession of cocaine. The court affirmed the remaining convictions. View "Watkins v. State" on Justia Law

A woman who had been in a long-term romantic relationship with a child's legal mother sought joint legal custody and parenting time under Georgia's Equitable Caregiver Statute, OCGA § 19-7-3.1, after the couple broke up. The statute allows a non-parent to seek custody or visitation rights if they have undertaken a parental role and developed a bonded and dependent relationship with the child, supported by a parent. The child's mother challenged the constitutionality of the statute and the sufficiency of the evidence supporting the trial court's order.The Superior Court granted the woman's request for equitable caregiver status, finding that she had established a bonded and dependent relationship with the child and that the child would suffer long-term emotional harm without continued contact. The court awarded joint legal custody and parenting time to the woman, despite the mother's objections.The Supreme Court of Georgia reviewed the case and raised concerns about the constitutionality of the Equitable Caregiver Statute, particularly regarding the fundamental right of parents to the care, custody, and control of their children. The court noted that any waiver of this constitutional right must be knowing and voluntary, and that conduct prior to the statute's effective date could not constitute such a waiver. The court concluded that the statute does not authorize trial courts to confer equitable caregiver status based on conduct by the legal parent that took place before the statute's effective date.The Supreme Court of Georgia reversed the trial court's order, holding that the Equitable Caregiver Statute does not apply to parental conduct occurring before its effective date. The court did not resolve the constitutional questions but based its decision on statutory construction and the doctrine of constitutional avoidance. View "DIAS v. BOONE" on Justia Law

Dontarious Burke was convicted of malice murder and armed robbery for the shooting death of Kentrell Jones. The incident occurred on November 27, 2019, and Burke was indicted on March 1, 2021. His trial was severed from his brother DeMarcus Burke's trial. Burke was tried by a jury from October 19 to 20, 2021, and found guilty on all counts. He was sentenced to life in prison for malice murder and an additional 20 years for armed robbery. Burke filed a motion for a new trial, which was denied by the trial court on May 6, 2024. He then filed a timely notice of appeal.The trial court denied Burke's motion for a new trial, and he appealed to the Supreme Court of Georgia. Burke raised several claims, including a violation of his Sixth Amendment rights under the Confrontation Clause, ineffective assistance of counsel, and the cumulative effect of errors requiring a new trial. The trial court had admitted testimony from police officers about information obtained from non-testifying witnesses, which Burke argued violated his Confrontation Clause rights. However, because Burke did not raise this objection at trial, the Supreme Court reviewed it for plain error and found none.The Supreme Court of Georgia reviewed Burke's claims and found that none of them warranted a reversal of his convictions. The court held that Burke's Confrontation Clause rights were not violated, as the testimony in question did not clearly and obviously violate established law. Additionally, the court found that Burke's trial counsel did not render ineffective assistance, as the decisions made by counsel were within the bounds of reasonable trial strategy. Finally, the court determined that there was no cumulative error that would require a new trial. Consequently, the Supreme Court of Georgia affirmed Burke's convictions. View "BURKE v. THE STATE" on Justia Law

In 2022, the Georgia General Assembly enacted House Bill 839 (HB 839), which incorporated the City of Mableton within unincorporated Cobb County and provided for the creation of one or more community improvement districts (CIDs) within Mableton. Deidre White and other residents of Cobb County challenged the constitutionality of HB 839, arguing that it violated the "Single Subject Rule" of the Georgia Constitution by creating more than one unit of government, specifically Mableton and the CIDs.The trial court dismissed the complaint for failure to state a claim upon which relief could be granted. The court found that HB 839 did not violate the Single Subject Rule, as the creation of CIDs within Mableton was germane to the overall objective of incorporating the city. The Appellants then appealed this decision.The Supreme Court of Georgia reviewed the case and affirmed the trial court's dismissal. The court held that HB 839 did not violate the Single Subject Rule because the creation of CIDs within Mableton had a logical and natural connection to the incorporation of the city. The court also rejected the argument that the ballot question for HB 839 contravened the precedent set in Rea v. City of LaFayette, as the creation of CIDs was related to the single objective of establishing Mableton. Thus, the court concluded that HB 839 was constitutional and upheld the trial court's decision. View "WHITE v. CITY OF MABLETON" on Justia Law

Tico Holloway was convicted of malice murder and related crimes in connection with the shooting death of Mercedes Dejesus Antunez-Flores and violent crimes against N.H. and M.H. The crimes occurred on August 17, 2019. Holloway was indicted on multiple counts, including malice murder, felony murder, criminal attempt to commit armed robbery, aggravated assault, aggravated battery, armed robbery, and possession of a firearm by a convicted felon. A jury found Holloway guilty of all counts except armed robbery. He was sentenced to life in prison without parole for malice murder, with additional concurrent sentences for other charges. Holloway's motion for a new trial was denied, and he appealed.The trial court, Cobb County, denied Holloway's motion for a new trial. Holloway argued that the evidence was insufficient to support his malice murder conviction and that the trial court made errors. He claimed the evidence did not disprove his self-defense argument beyond a reasonable doubt. Holloway also contended that the trial court erred by allowing the medical examiner to testify remotely via videoconference, which he argued violated his Sixth Amendment right to confrontation. Additionally, he claimed that errors in the Spanish-to-English interpretation of M.H.'s testimony violated his right to a fair trial.The Supreme Court of Georgia reviewed the case and affirmed the lower court's decision. The court held that the evidence was sufficient to support Holloway's malice murder conviction, as the jury was entitled to reject his self-defense claim. The court also found no plain error in allowing the medical examiner to testify remotely, noting that Holloway had consented to this procedure. Finally, the court concluded that Holloway waived his claim regarding the interpretation errors by agreeing to the procedure used during the trial. View "HOLLOWAY v. THE STATE" on Justia Law

Sherran Wasserman agreed to sell land in Franklin County to Anthony Pham, contingent on the approval of a conditional use permit by the Franklin County Board of Commissioners. Pham applied for the permit to build and operate chicken houses, but the Board denied the application. Wasserman then sued the Board and the County, initially bringing multiple claims under state and federal law. She dismissed some claims, conceded others, and the trial court dismissed her remaining state-law claims due to sovereign immunity. This left two federal claims: one alleging the County violated Pham’s equal protection rights based on race, and another alleging a violation of Wasserman’s equal protection rights as a “class of one.”The trial court denied the County’s motion for summary judgment, applying the federal doctrine of third-party standing, which allows a plaintiff to assert the rights of third parties. The court found genuine issues of material fact precluded summary judgment on standing and the merits of Wasserman’s equal protection claims. The Court of Appeals reversed, concluding Wasserman lacked third-party standing and that her “class of one” claim failed as a matter of law.The Supreme Court of Georgia reviewed whether a plaintiff may rely on the federal doctrine of third-party standing to establish constitutional standing in Georgia courts. The court held that Georgia’s constitutional standing requirements, rooted in the common law and consistent precedent, do not allow a plaintiff to maintain an action by asserting only the rights of a nonparty. The court overruled its previous adoption of the federal doctrine of third-party standing, concluding that a plaintiff must assert her own legal rights to invoke the judicial power of Georgia courts. The judgment was vacated and remanded for further proceedings consistent with this opinion. View "WASSERMAN v. FRANKLIN COUNTY" on Justia Law

Ammon Sumrall was convicted in October 1992 by a DeKalb County jury of felony murder, armed robbery, and other crimes related to the shooting death of Wade Barrett, Jr. on April 7, 1991. He was sentenced to two consecutive life sentences plus five additional years. Over 30 years later, Sumrall filed a pro se petition in the Superior Court of DeKalb County seeking retroactive first-offender treatment based on an amendment to OCGA § 42-8-66. He also filed a motion to declare the statute unconstitutional.The trial court initially dismissed Sumrall’s petition and motion, but later vacated this order and issued an amended order. The amended order dismissed the petition for failing to obtain the necessary consent from the prosecuting attorney and denied the motion to declare the statute unconstitutional, citing a lack of standing and insufficient supporting arguments.The Supreme Court of Georgia reviewed the case and affirmed the trial court’s decisions. The court held that Sumrall failed to meet the statutory requirement of obtaining the prosecuting attorney’s consent before filing his petition for retroactive first-offender treatment. The court also found no merit in Sumrall’s argument that the prosecuting attorney’s inaction constituted implied consent. Additionally, the court upheld the trial court’s denial of Sumrall’s motion to declare OCGA § 42-8-66 (a) (1) unconstitutional, concluding that Sumrall did not demonstrate a clear and palpable conflict with the Georgia or United States Constitutions. The court emphasized that the statute did not deprive Sumrall of his right to access the courts or to be heard. View "Sumrall v. State" on Justia Law