Justia Georgia Supreme Court Opinion Summaries

Edward Behl was convicted by jury for felony murder and a weapons charge stemming from the 2017 death of Joseph Billings, a fellow resident of a homeless encampment. Behl argued for a new trial on the grounds that: (1) the trial court plainly erred in not charging the jury on voluntary manslaughter; and (2) Behl was unable to view digital discovery while incarcerated and while exercising the right to self-representation. After review, the Georgia Supreme Court concluded the trial court did not plainly err in failing to charge the jury on voluntary manslaughter, and that Behl did not preserve the issue of access to discovery. Accordingly, judgment and conviction were affirmed. View "Behl v. Georgia" on Justia Law

Twice previously, Dennis Allaben appealed his conviction for malice murder arising from the strangulation death of his wife, Maureen. On each appeal, the Georgia Supreme Court reversed the conviction and remanded the case, and the case was retried. After Allaben’s third trial was held in December 2016, a jury found him guilty of malice murder, and he again appealed, arguing that the evidence was insufficient to support his conviction for murder and that the State failed to prove venue as required by OCGA § 17-2-2. Finding no reversible error, the Supreme Court affirmed the conviction. View "Allen v. Georgia" on Justia Law

Israel Timothy Williams was convicted by jury of malice murder and possession of a firearm during the commission of a felony in connection with the shooting death of Brandon Colson. Williams challenged the sufficiency of the evidence, contended his trial counsel was ineffective, and argued that the trial court erred in denying his request for a jury instruction on coercion. Because the Georgia Supreme Court found Williams failed to carry his burden of showing reversible error, it affirmed his convictions as well as the trial court’s order denying his motion for a new trial. View "Williams v. Georgia" on Justia Law

Steven Monroe appealed his convictions for malice murder and related offenses arising out of the 2014 shooting death of Clayton Cross and aggravated assaults of Kenneth Minson, Darius Minson, Willie Calhoun, Muhammad Clark, Dominique Ellis, and Craig Harris. Monroe claimed on appeal the evidence was insufficient to support his convictions for violating Georgia’s Gang Act and his convictions on all counts related to Clark. Monroe further alleged the trial court abused its discretion by denying his motion for mistrial based upon alleged juror misconduct, erred by failing to charge the jury on self-defense, improperly admitted opinion evidence at trial, and erred during sentencing. Monroe also alleged he received ineffective assistance of counsel. The Georgia Supreme Court determined the trial court erred in calculating Monroe's sentence, but affirmed the convictions in all other respects. The case was remanded for correction of Monroe's sentence. View "Monroe v. Georgia" on Justia Law

Chad Haufler was convicted by jury in 2021 of malice murder and other crimes in connection with the shooting death of Marc Dimos. On appeal, Haufler argued the trial court erred in failing to instruct the jury on involuntary manslaughter and in denying his pretrial motion to suppress certain statements he made in the presence of law enforcement officers. Finding no reversible error, the Georgia Supreme Court affirmed. View "Haufler v. Georgia" on Justia Law

After Marina Middlebrooks pleaded not guilty by reason of insanity to charges arising from the stabbing death of her daughter, Sky Allen, a jury found Middlebrooks guilty of murder and cruelty to children in the first degree. On appeal, Middlebrooks contended that the trial court erred in allowing the State’s expert witness to testify as to what happens when a person is found not guilty by reason of insanity. In addition, Middlebrooks contended “[t]he trial court erred in restricting the testimony of [her] diagnosing psychiatrist,” an employee of the Department of Veterans’ Affairs (“VA”), “without following the correct procedure” under federal regulations concerning the testimony of VA personnel in legal proceedings. In a related claim, Middlebrooks contended her “trial counsel was ineffective in failing to object to the limitation of [the witness’s] testimony by the [f]ederal [g]overnment and the [p]rosecutor.” Finding no reversible error, the Georgia Supreme Court affirmed. View "Middlebrooks v. Georgia" on Justia Law

Appellant Robert Gonzales challenged his convictions for aggravated battery and felony murder, predicated on cruelty to children in the first degree, in connection with the death of three-year-old Samuel Carroll, the son of Appellant’s girlfriend Jocelyn Carroll. Appellant contended the evidence was insufficient to support his convictions. After review, the Georgia Supreme Court concluded that the evidence presented at trial was legally sufficient to support Appellant’s convictions as a matter of constitutional due process. However, the Court vacated Appellant’s sentence for aggravated battery because this count should have merged with the felony murder conviction under these particular facts. View "Gonzales v. Georgia" on Justia Law

Appellant Jaquest Norris challenged his 2018 convictions for felony murder and cruelty to children in the first degree in connection with the beating death of a child, eight-month-old Monte Jones. Norris contended the evidence was legally insufficient to support his convictions. Appellant also contended his trial counsel provided constitutionally ineffective assistance by failing to impeach one of the State’s expert witnesses, Dr. Deborah Young, with evidence that Monte had two healed fractures in his left leg after Dr. Young testified that she recalled Monte having only recent fractures. Because the Georgia Supreme Court concluded the evidence was legally sufficient to sustain Appellant’s convictions, and because Appellant failed to show prejudice from any alleged deficiency in trial counsel’s actions, the convictions were affirmed. View "Norris v. Georgia" on Justia Law

Jeremy Taylor was convicted by jury of the malice murder of Eric Bolar and the aggravated battery of Seaborn Roberts. Taylor raised five claims of error on appeal: that (1) the trial court abused its discretion by excluding evidence about Taylor’s mental health; (2) the trial court erred by sentencing Taylor based on an inference that Taylor did not accept responsibility or feel remorse for his crimes because he did not plead guilty; (3) the trial court abused its discretion by denying Taylor’s motion for a mistrial after a defense witness opined on the legal definition of aggravated battery; (4) Taylor received ineffective assistance of counsel because his lawyer did not investigate and present an insanity defense; and (5) Taylor received ineffective assistance of counsel because his lawyer failed to introduce mitigation evidence based on Taylor’s mental health. Finding no reversible error, the Georgia Supreme Court affirmed Taylor’s convictions and sentences. View "Taylor v. Georgia" on Justia Law

Fred Charles appealed his convictions for malice murder and related offenses in connection with the July 2015 shooting death of Stephanie Daniel. Charles argued: (1) the trial evidence was insufficient to support his convictions; (2) the trial court failed to appropriately question jurors regarding a potential issue of juror irregularity; (3) the trial court erred in denying his pretrial motion to bifurcate the trial and try separately the charges for which his status as a felon was material; and (4) trial counsel was ineffective for failing to object to the State using a felon-in-possession-of-a-firearm charge as a predicate for felony murder. Finding no reversible error, the Georgia Supreme Court affirmed. View "Charles v. Georgia" on Justia Law