Justia Georgia Supreme Court Opinion Summaries

Patrick Middleton moved to suppress evidence obtained during a search by Officer Amanda Graw of the Kingsland Police Department (“KPD”), arguing that she did not have authority to stop or search him because she was outside the territorial jurisdiction of the KPD. Officer Graw claimed that she did have authority to perform the stop and search because she had been deputized by the Camden County Sheriff’s Office (“CCSO”) seven years earlier. After the trial court granted the motion to suppress, the State appealed. The Court of Appeals reversed, concluding that Officer Graw had presented sufficient evidence of her deputization. After its review, the Georgia Supreme Court vacated the Court of Appeals’ opinion with direction that it vacate the trial court’s order and remand the case to the trial court with direction to clarify its basis for ruling that the search and seizure of Middleton was unlawful. View "Middleton v. Georgia" on Justia Law

In 2009, a jury convicted David Edenfield for the 2007 sexual assault and murder of six-year-old Christopher Barrios, and the jury imposed a death sentence for the murder. Lead trial counsel, joined by other attorneys, represented Edenfield on direct appeal, and, in June of 2013, the Georgia Supreme Court affirmed Edenfield’s convictions and sentences on direct appeal. Edenfield subsequently filed a petition for a writ of habeas corpus, asserting he was ineligible for the death penalty because he is intellectually disabled and that trial counsel provided constitutionally ineffective assistance during his trial in several ways, including by failing to present evidence of Edenfield’s alleged intellectual disability in the sentencing phase as mitigating evidence. He also contended that appellate counsel had provided ineffective assistance. The habeas court denied relief on all claims except for the ineffective assistance of trial counsel claim concerning counsel’s presentation of evidence of Edenfield’s alleged intellectual disability as mitigating evidence in the sentencing phase. Based on that claim, the habeas court vacated Edenfield’s death sentence. The Warden appealed in Case No. S23A0260, and Edenfield has cross-appealed in Case No. S23X0261. In the Warden’s appeal, the Georgia Supreme Court reversed the habeas court’s decision to vacate Edenfield’s death sentence. In Edenfield’s cross-appeal, the Court affirmed in part; the Court conclude as to Edenfield’s claim regarding trial counsel’s alleged deficiency concerning certain allegedly mitigating circumstances that additional findings of fact and conclusions of law were required, and the case was therefore remanded to the habeas court for further proceedings. View "Caldwell v. Edenfield" on Justia Law

Jose Basulto appealed his convictions for felony murder and aggravated assault stemming from an incident in which he drove his truck into several pedestrians after a bar fight. Basulto’s actions resulted in the deaths of two of the pedestrians, and left a third seriously injured. Basulto’s only argument on appeal was that the trial court erred by refusing to remove a juror who revealed new information about the juror’s criminal history after being selected for the jury. Because it found the trial court did not abuse its discretion in failing to remove the juror, the Georgia Supreme Court affirmed. View "Basulto v. Georgia" on Justia Law

Quavion Rountree appealed his conviction for malice murder in connection with the 2019 shooting death of Anahitdeep Singh Sandhu. Rountree contended on appeal that the trial court erred in failing to charge the jury on voluntary manslaughter and on mutual combat. Because Rountree failed to carry his burden of showing plain error, the Georgia Supreme Court affirmed. View "Rountree v. Georgia" on Justia Law

Reginald Johnson was convicted of felony murder and first-degree cruelty to children in connection with the 2016 death of his six-month-old daughter, Jordan. On appeal, Johnson contended that (1) the evidence was insufficient to support his convictions; (2) the verdict was contrary to the law and evidence and strongly against the weight of the evidence; (3) the trial court erred by admitting certain photographs taken before and during the autopsy; (4) the trial court erred by limiting the defense’s cross-examination of Jordan’s mother; (5) the trial court erred by allowing certain testimony by the medical examiner; (6) the trial court erred by excluding testimony about the defense’s unsuccessful effort to procure a witness; and (7) the trial court committed plain error by failing to give a jury instruction on accident. Finding no reversible error, the Georgia Supreme Court affirmed Johnson's conviction. View "Johnson v. Georgia" on Justia Law

Demarcus Brinkley was charged with the kidnapping, attempted rape, and murder of Mariam Khalid Abdulrab. After the police identified him as a suspect for those crimes, Brinkley fled, leading officers in a high speed car chase. During the chase, Brinkley apparently told his mother on the phone that he did not want to pull over because he did not want to go back to prison. The trial court granted Brinkley’s pretrial motion to exclude this statement under OCGA § 24-4-403, and the State appealed. Because the Georgia Supreme Court concluded the trial court misapplied the Rule 403 standard, it vacated the trial court's order and remanded for further consideration under the correct standard. View "Georgia v. Brinkley" on Justia Law

Appellants Durell Muse, Darious Harris, and Darious’s Jujuane Harris, appealed their convictions following a joint trial for malice murder and other crimes stemming from the shooting death of Antonio Clements, the shooting of Clements’ girlfriend, Kendra Clopton, and the firing of shots that struck a vehicle occupied by Silento Bell and Yolanda Davis. On appeal, all Appellants challenged the sufficiency of the evidence to support certain of their convictions; contended that the trial court violated the continuing witness rule by allowing the jury to watch surveillance videos in the jury room during deliberations; and claimed that the trial court violated certain of their rights when addressing notes from the jury. In addition, Muse and Darious contended the trial court erred by failing to exclude evidence extracted from Muse’s cell phone; Muse contended his trial counsel was ineffective in failing to raise a hearsay objection to testimony from a State’s witness; Darious and Jujuane contended the trial court erred in failing to sever their trials; and Darious contended he was entitled to a new trial because the trial court erred in failing to exclude the testimony of a State’s witness and because the State represented during the motion for new trial proceedings that the record was incomplete. Finding no reversible error, the Georgia Supreme Court affirmed in all three appeals. View "Muse, et al. v. Georgia" on Justia Law

Appellant Philip Pugh entered a plea of guilty but mentally ill to malice murder in connection with the shooting death of Vincent Newsome. On appeal, Pugh claimed the trial court erred in denying his motion to withdraw his guilty but mentally ill plea for three reasons: (1) the trial court should have sua sponte conducted a competency hearing at the time of his guilty plea and that the failure to do so violated his procedural due process rights; (2) his substantive due process rights were violated by the trial court’s acceptance of the plea because Pugh was not competent to enter the plea and did not enter the plea voluntarily; and (3) he received constitutionally ineffective assistance of counsel in that plea counsel failed to request a competency hearing. The Georgia Supreme Court found that given Pugh’s repeated assertions at the time of the plea that he was being threatened and forced into entering the plea, the State failed to meet its burden to show that his plea was knowing and voluntary. The Court therefore reversed Pugh’s conviction and remanded the case for further proceedings. View "Pugh v. Georgia" on Justia Law

Anthony Perryman-Henderson was convicted of malice murder and other crimes in connection with the 2017 shooting death of Tanaya Dunlap. On appeal, Perryman-Henderson contended: (1) his trial counsel provided ineffective assistance by failing to “correct” the medical examiner’s testimony about the range the fatal shot was fired from; and (2) the trial court committed plain error by commenting on the State’s characterization of the medical examiner’s range-of-fire testimony in a way that could be taken as endorsement of it. Finding no reversible error, the Georgia Supreme Court affirmed Perryman-Henderson's convictions. View "Perryman-Henderson v. Georgia" on Justia Law

Rico King was convicted by jury of the 2018 malice murder of Michael Brooks and possession of a firearm during the commission of a felony based on shooting Brooks. King argued on appeal: (1) that the trial court erroneously denied King’s motion for a new trial on the “general grounds”; (2) the trial court should not have allowed witness testimony and closing arguments about voluntary intoxication; (3) the trial court plainly erred by admitting character evidence about King’s alleged past alcohol and illegal drug use; and (4) that King received constitutionally ineffective assistance of counsel. Finding no reversible error, the Georgia Supreme Court affirmed King's convictions. View "King v. Georgia" on Justia Law