Justia Georgia Supreme Court Opinion Summaries

The Georgia Supreme Court granted certiorari to consider whether the warrantless search of Richard Caffee resulting in the discovery of marijuana was authorized by an exception to the Fourth Amendment’s warrant requirement. The Court of Appeals concluded that the warrantless search was permissible because it was supported by probable cause to believe that marijuana would be found on Caffee. “Absent consent, probable cause generally is a necessary condition to support a warrantless search of a person, but it is not by itself sufficient; a warrantless search must also fall within a recognized exception to the warrant requirement.” To the extent the Court of Appeals suggested otherwise, the Supreme Court determined it was wrong. Nevertheless, the Supreme Court affirmed because the warrantless search was permissible as a search incident to arrest (even though it preceded the formal arrest) as the police officer had developed probable cause to arrest Caffee for possession of marijuana before conducting the search. View "Caffee v. Georgia" on Justia Law

Ashleigh Ricks appealed the denial of her 2017 motion for an out-of-time appeal of her guilty-plea conviction for felony murder. The Georgia Supreme Court reversed, concluding that the trial court was without jurisdiction to decide the motion. View "Ricks v. Georgia" on Justia Law

Appellant Latisha McCoy was charged with driving under the influence of marijuana to the extent it was less safe to drive after she was stopped at a roadblock in Henry County, Georgia. She moved to suppress all evidence obtained from the stop and arrest on the ground that the roadblock violated the Fourth Amendment. The trial court denied McCoy’s motion, and following a bench trial, found her guilty. She appealed; the Court of Appeals affirmed the trial court’s denial of her motion to suppress. The Georgia Supreme Court granted McCoy’s petition for certiorari on whether the Court of Appeals erred in its application of LaFontaine v. Georgia, 497 SE2d 367 (1998), in determining whether the roadblock was reasonable under the Fourth Amendment, in particular the factor that considered the screening officer’s training and experience. Although the Supreme Court did not follow the analysis employed by the Court of Appeals, it affirmed the judgment, and in doing so, clarified the factors needed to determine whether a roadblock is reasonable under the Fourth Amendment. View "McCoy v. Georgia" on Justia Law

The Georgia Supreme Court granted certiorari in this case to address whether Georgia’s new Juvenile Code required a party to follow the interlocutory appeal procedures laid out in OCGA 5-6-34 (b) when appealing an order concerning the transfer of a case from juvenile to superior court. The Court held that it did not and, in so doing, reversed the decision of the Court of Appeals and remanded the case to be decided on the merits. View "In the Interest of K.S., a child" on Justia Law

This case was a “John Doe” appeal from the denial of a motion to seal the records of a criminal case pursuant to OCGA 35-3-37 (m). In July 2006, Doe pled guilty to possession of marijuana as a first-time drug offender and was sentenced to five years on probation without entry of a judgment of guilt The Court of Appeals transferred the appeal to the Georgia Supreme Court on the sole basis of the Supreme Court’s exclusive appellate jurisdiction in "all cases in which the constitutionality of a law, ordinance, or constitutional provision has been drawn in question." After review, the Supreme Court concluded this appeal did not invoke its Court’s constitutional-question jurisdiction, and accordingly, returned the case to the Court of Appeals. View "Doe v. Georgia" on Justia Law

Appellant Anthony Lee Douglas was convicted of malice murder and associated offenses in connection with the shooting deaths of Keith Davis and Charles Avent and the wounding of Sheldon Thomas. On appeal, Appellant contended that the trial court erroneously denied his motion to suppress and improperly admitted other acts evidence under OCGA 24-4-404 (b). Though the Georgia Supreme Court concluded Appellant was erroneously sentenced, the Court otherwise affirmed, and remanded for resentencing. View "Douglas v. Georgia" on Justia Law

Stephanie Stephens appealed several convictions stemming from the death of her child, Jewell, from cocaine poisoning. Stephens was ultimately sentenced on only one count, felony murder predicated on possession of cocaine with intent to distribute. She argued the evidence was insufficient on that count because the State failed to prove a nexus between the underlying felony and her child’s death. The Georgia Supreme Court rejected that argument, and the same argument in the appeal of her co-defendant, with whom Stephens was tried jointly. Her remaining arguments addressed counts that the trial court merged or effectively vacated, and thus are moot. As such, the Supreme Court affirmed the conviction. View "Stephens v. Georgia" on Justia Law

Appellant Clifford White was found guilty of murdering his wife, Linda in 2008. She was discovered by appellant’s brother-in-law in a freezer, partially dressed with a bag over her head. The cause of death was listed as blunt force trauma to the head. Appellant appealed his conviction, arguing the evidence was insufficient to sustain his malice murder conviction, and that he received ineffective assistance of trial counsel. Finding no reversible error, the Georgia Supreme Court affirmed. View "White v. Georgia" on Justia Law

Darrell Hendrix was convicted by jury for felony murder, drug-related and gang-related crimes. On appeal to the Georgia Supreme Court, he contended the evidence was insufficient and that the trial court erred by admitting certain witness testimony pursuant to OCGA 24–8–804 (b) (5). After review of the specific facts of this case, the Georgia Court found the evidence admitted was sufficient to support Hendrix’s convictions, and affirmed. View "Hendrix v. Georgia" on Justia Law

Damion Clayton was shot and killed in a baseball park in Macon. In March 2014, a grand jury indicted Appellant Jedarrius Meadows, Roland Watson, and Trayvon Starks for malice murder and felony murder; in June, they were reindicted on those two murder charges along with aggravated assault, armed robbery, and two counts of gang activity. Appellant’s trial was severed, and his co-indictees agreed to testify for the State. Appellant challenged the trial court’s denial of his plea in bar based on double jeopardy after the court, sua sponte and over Appellant’s objection, declared a mistrial of his murder trial during jury deliberations. In its order denying the plea, the court said that the deliberations were contentious and that it declared the mistrial “in the interest of juror safety.” Having reviewed the record, the Georgia Supreme Court concluded the trial court declared the mistrial without sufficient factual support and without considering less drastic alternatives to terminating the trial. Because there was no manifest necessity for a mistrial, the Supreme Court reversed the denial of the plea in bar. View "Meadows v. Georgia" on Justia Law