Justia Georgia Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Locklear v. Georgia
Tony Locklear was convicted by jury of the malice murder of William Long, concealing a death, and related charges. On appeal, Locklear challenged the sufficiency of the evidence supporting his convictions. He also argued that the trial court erred by: (1) failing to suppress statements made during his custodial interview; (2) denying his motion to suppress certain physical evidence; (3) providing a confusing verdict form to the jury; and (4) refusing to grant a mistrial after the prosecutor made improper comments during closing arguments. Because the evidence was clearly sufficient to support Locklear’s convictions and because the trial court committed no reversible error with respect to Locklear’s other enumerations of error, the Georgia Supreme Court affirmed. View "Locklear v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Morris v. Georgia
Appellant Jerrontae Morris was convicted of malice murder and related crimes in connection with the November 2015 shooting of a vehicle occupied by Anthony Lundy and Demeco Person, which fatally wounded Lundy. On appeal, Appellant contended the evidence was insufficient as a matter of constitutional due process to sustain his conviction for malice murder because the State failed to prove that Appellant proximately caused the victim’s death and did not prove that Appellant either conspired with his co-defendants to commit the crime or was a party to the crime. Appellant also contends that the evidence was insufficient as a matter of Georgia statutory law to sustain his conviction for malice murder because the trial evidence was circumstantial and the State failed to exclude every reasonable hypothesis other than his guilt. The Georgia Supreme Court found no reversible errors and affirmed the convictions. View "Morris v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Jackson v. Georgia
Appellant Quentin Jackson was convicted of malice murder and related charges in connection with the shooting death of Darian Brewster. On appeal, Jackson argued: (1) the evidence was insufficient; (2) his trial counsel provided constitutionally ineffective assistance in several respects; and (3) the trial court erred by failing to instruct the jury on accomplice corroboration. The Georgia Supreme Court found no reversible errors and affirmed the convictions. View "Jackson v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Henderson v. Georgia
After a joint trial, Demetre Mason and Frankland Henderson were convicted of malice murder and other crimes in connection with the 2014 shooting deaths of Sonia Williams and Shaniqua Camacho. On appeal, Mason contended the evidence was not sufficient to support his convictions for malice murder, and that the trial court should have held a hearing to determine whether evidence that, a month before the murders, Mason stole a handgun that was used in the shootings was admissible under Rule 403. In a separate appeal, Henderson raised six claims: (1) the admission at trial of Mason’s out-of-court statement to police violated Henderson’s rights under the Confrontation Clause of the Sixth Amendment; (2) the trial court should have given an instruction limiting how the jury could consider Mason’s out-of-court statement; (3) the testimony of one witness for the prosecution, who he claimed was an accomplice, was insufficiently corroborated; (4) the trial court should have excluded as hearsay testimony about statements from an associate of Henderson and Mason, because there was insufficient evidence to show that the statements were made in furtherance of a conspiracy so as to fall within a hearsay exception; (5) the trial court abused its discretion in denying Henderson’s motion to sever his case; and (6) the trial court abused its discretion in admitting photos of Henderson making gang signs without proper authentication.The Georgia Supreme Court found no reversible errors in either case and affirmed the convictions. View "Henderson v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Reese v. Georgia
Larry Reese was convicted by jury of the 2015 malice murder of Claynesia Ringer, possession of a firearm during the commission of a felony based on shooting Ringer, and possession of marijuana with intent to distribute. Reese argued on appeal: (1) the trial court plainly erred by failing to instruct the jury on justification, no duty to retreat, and the State’s burden to disprove affirmative defenses; (2) the trial court plainly erred by not giving an accomplice corroboration charge; and (3) Reese received constitutionally ineffective assistance of counsel. Seeing no error, the Georgia Supreme Court affirmed. View "Reese v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Young v. Georgia
Tomarkus Young was convicted by jury of felony murder and other charges in connection with the 2018 shooting death of Richard Anderson. On appeal, Young argued the evidence was constitutionally insufficient to support his convictions; that the trial court erred in denying his motion to strike a potential juror; that he received ineffective assistance of counsel; and that cumulative errors require the grant of a new trial. Finding these assertions lacked merit, the Georgia Supreme Court affirmed. View "Young v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Hatcher v. Georgia
Perry Lee Hatcher, Jr., was convicted by jury of felony murder and cruelty to children in the third degree in connection with the shooting death of his wife, Dashea Hatcher, in the presence of their son, M. H. Hatcher contended his attorney was ineffective for failing to object to the qualifications of the State’s expert witness and to rebut the expert’s opinion concerning fibers found on the murder weapon. Because Hatcher failed to carry his burden of showing ineffective assistance of counsel, The Georgia Supreme Court affirmed the trial court’s order denying his motion for a new trial. View "Hatcher v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Moulder v. Georgia
Joshua Moulder was convicted of malice murder, armed robbery, and possession of a firearm during the commission of a felony in connection with the July 2006 shooting death of Anthony Rudolph and was also convicted of influencing a witness in 2014. He appealed, arguing the evidence was not sufficient to support his convictions related to the 2006 shooting and that counsel provided ineffective assistance by: not arguing that the State failed to prove the statute of limitation tolling provision alleged for the non-murder crimes committed in 2006; failing to raise a hearsay and Confrontation Clause objection to certain testimony given by the lead detective; failing to correctly advise Moulder about whether his prior convictions could be used to impeach him if he testified; inaccurately describing the reasonable-doubt standard in closing argument; and failing to object to a jury charge about statements made during formal court proceedings. Because the evidence was sufficient to support Moulder’s convictions and he has failed to prove his claims of ineffective assistance of counsel, the Georgia Supreme Court affirmed. View "Moulder v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Wood v. Georgia
Appellant Bobby Wood, Jr. was convicted of felony murder in connection with the 2020 shooting death of Aaron Skinner. On appeal, Appellant contended: (1) the trial court abused its discretion in denying him the opportunity to cross-examine the State’s expert witness about Skinner’s alleged arrest for criminal trespass on the day before the shooting; (2) the trial court violated his right to due process by denying him access to certain physical evidence post-trial; (3) trial counsel was ineffective for failing to object to the State’s redirect examination of the State’s expert witness as outside the scope of redirect examination; and (4) the cumulative effect of the alleged errors committed by the trial court and trial counsel deprived Appellant of a fair trial. Finding no reversible error, the Georgia Supreme Court affirmed. View "Wood v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Allen v. Georgia
Sean Allen appealed his conviction for felony murder for the 2021 shooting death of Daquan Gillett. Allen argued: (1) the trial court erred when it failed to grant him immunity from prosecution based on self-defense; (2) the evidence presented at trial was insufficient to support his conviction; (3) the trial court erred by limiting his ability to argue the law of self-defense in closing argument; and (4) trial counsel was ineffective in several respects. Finding no reversible error, the Georgia Supreme Court affirmed. View "Allen v. Georgia" on Justia Law
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Constitutional Law, Criminal Law