Justia Georgia Supreme Court Opinion Summaries

Matthew Copeland was convicted of felony murder and related crimes in connection with the 2012 shooting death of Carlos Glenn. Copeland contended that the evidence was constitutionally insufficient to support his convictions and that his trial counsel rendered constitutionally ineffective assistance. The Georgia Supreme Court found the evidence was sufficient: the only disputed question was whether the shooting was justified, and the jury was entitled to discredit Copeland’s testimony that he shot Glenn in self-defense. And, although trial counsel admitted he relied on outdated precedent in seeking the admission of evidence about Glenn’s criminal convictions, the Court determined Copeland failed to establish that such evidence would have been admissible even under the applicable standard, so he has not shown the prejudice necessary to prevail on his claim of ineffective assistance. The Court therefore affirmed his convictions and sentence. View "Copeland v. Georgia" on Justia Law

Undrea Burley was convicted by jury of felony murder in connection with the beating death of Joshua Brooks. Burley contended the trial court plainly erred by failing to instruct the jury sua sponte on the elements of malice murder because the indictment charged Burley and his co-defendants, Wesley Adams and Demetrious Smith, with felony murder predicated on “aggravated assault with intent to murder.” The Georgia Supreme Court found the trial court’s instructions concerning the offenses of felony murder and aggravated assault with intent to murder, though erroneous, did not constitute plain error requiring reversal. Therefore, the Court affirmed the judgment of conviction. View "Burley v. Georgia" on Justia Law

Geovanni Perez was convicted of felony murder and a firearm offense in connection with the 2018 shooting death of Rahmier Gardner. Perez contended on appeal: (1) that the evidence was constitutionally insufficient to support his conviction for felony murder based on armed robbery; (2) the trial court erred by denying his motions to suppress certain evidence; and that he was improperly sentenced. Seeing no error, the Georgia Supreme Court affirmed. View "Perez v. Georgia" on Justia Law

Five University System of Georgia (“USG”) professors filed suit to block a 2017 statutory amendment that removed public colleges and other public postsecondary educational institutions from the statutory definition of “school safety zone.” Before the 2017 amendment, carrying or possessing a weapon on any real property or in any building owned by or leased to any postsecondary educational institution was a misdemeanor, and the 2017 amendment decriminalized that conduct. The professors alleged that, as a result of the 2017 amendment, the Code required the Board of Regents, the USG, and USG institutions to permit persons to carry or possess weapons on the campuses of public postsecondary educational institutions, contrary to longstanding USG policies. The professors sought a declaration that the statutory amendment was unconstitutional as applied because it usurped the Board’s constitutional authority to govern, control, and manage the USG and its member institutions. The trial court granted the State's motion to dismiss the complaint and denied the professors’ request for declaratory relief, ruling that the trial court lacked jurisdiction on three alternative grounds, including mootness. The Georgia Supreme Court found that because the complaint showed that the Board adopted gun-carrying policies consistent with the 2017 statutory amendment, the question of whether the amendment usurped the constitutional authority of the Board to govern, control, and manage the USG and its member institutions became moot. Consequently, the trial court lacked jurisdiction to adjudicate the professors’ as-applied challenge, and the judgment dismissing the professors’ complaint on that basis was affirmed. View "Knox v. Georgia" on Justia Law

Appellant Dennaryl Head was convicted of felony murder and other crimes in connection with the 2006 shooting death of Dwight Smith. On appeal, Head contended that: (1) the evidence presented at trial was legally insufficient to sustain the verdict against him under former OCGA § 24-4-8; and (2) the trial court abused its discretion under former OCGA § 24-3-1 by admitting hearsay testimony from a police detective. The Georgia Supreme Court concluded that the evidence was sufficient under former OCGA § 24-4-8 because the testimony of Head’s accomplice was sufficiently corroborated. "And, pretermitting whether the trial court erred in admitting the challenged testimony," the Court concluded any error was harmless. View "Head v. Georgia" on Justia Law

Appellant Garrett Davis was convicted of felony murder in connection with the 2012 shooting death of Eugene Stinchcomb. On appeal, Davis contended: (1) the evidence was legally insufficient to support his convictions; (2) his trial counsel provided constitutionally ineffective assistance; (3) the trial court erred by failing to instruct the jury on confession corroboration; and (4) the trial court erred by failing to grant a new trial based on prosecutorial misconduct. Finding no reversible error in the trial court's judgment, the Georgia Supreme Court affirmed. View "Davis v. Georgia" on Justia Law

Appellant Trevis Price was convicted by jury of malice murder and other offenses in connection with the deaths of L. C. Tumblin Jr. and Dexter Covin. On appeal, Price challenged the sufficiency of the evidence supporting his convictions for malice murder and the trial court’s denial of his motion to sever the charge for possession of cocaine with intent to distribute. Finding no reversible error in the trial court's judgment, the Georgia Supreme Court affirmed. View "Price v. Georgia" on Justia Law

In 2018, Mary Jackson and a nonprofit organization, Reaching Our Sisters Everywhere, Inc. (“ROSE”), filed a complaint against the Georgia Secretary of State challenging the constitutionality of the Georgia Lactation Consultant Practice Act (“the Act”), OCGA §§ 43-22A-1 to 43-22A-13. Under the Act, the Secretary issues licenses authorizing lactation care providers to provide lactation care and services for compensation. Only lactation care providers who obtain a privately issued certification as an International Board Certified Lactation Consultant (“IBCLC”) were eligible to obtain a license. Jackson and ROSE (collectively “Plaintiffs”) alleged their work included the provision of lactation care and services and that the Act was irrational and lacked any real and substantial connection to the public health, safety, or welfare because there was no evidence that non-IBCLC providers of lactation care and services ever harmed the public. They also contended the Act would require them to cease practicing their chosen profession, thus violating their rights to due process and equal protection under the Georgia Constitution. In the first round of this litigation, the trial court granted the Secretary’s motion to dismiss for failure to state a claim, but the Georgia Supreme Court reversed and remanded with direction. Following remand, the Secretary withdrew his motion to dismiss, and the parties engaged in discovery and filed cross-motions for summary judgment. On the due process claim, the trial court granted the Secretary’s motion for summary judgment, and on the equal protection claim, the trial court granted Plaintiffs’ motion. The Secretary appealed, and Plaintiffs filed a cross-appeal. The Supreme Court concluded in the cross-appeal that the Act was unconstitutional on due process grounds and that the trial court therefore erred in granting summary judgment to the Secretary and denying it to Plaintiffs. Accordingly, the Court reversed the trial court on the due process claim and did not reach the equal protection claim raised in the main appeal. View "Raffensperger v. Jackson, et al." 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

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