Justia Georgia Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Georgia v. Wilson
The State appealed the grant of defendant Roceam Wilson’s motion to suppress. Wilson was indicted for, among other things, murder in connection with the shooting death of Bradly Jordan. The State contended the trial court erred in concluding that the search warrant issued for Wilson’s cell phones was overbroad and authorized a general search in violation of the Fourth Amendment to the United States Constitution. In reviewing the trial court’s grant of the motion to suppress, “we apply the well-established principles that the trial court’s findings as to disputed facts will be upheld unless clearly erroneous and the trial court’s application of the law to undisputed facts is subject to de novo review.” Applying that standard here, the Georgia Supreme Court found no error in the trial court’s order. Accordingly, the order was affirmed. View "Georgia v. Wilson" on Justia Law
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Constitutional Law, Criminal Law
Bowman v. Georgia
In February 2014, a grand jury indicted Logan Bowman for crimes against his daughter. At the next term of court, Bowman properly invoked his right to a speedy trial pursuant to the Georgia speedy trial statute, OCGA § 17-7-170. More than five years later, the State still had not brought him to trial before 12 citizens sworn by the court or the court clerk to “well and truly try the issue formed upon this bill of indictment . . . and a true verdict give according to the evidence,” so Bowman moved for discharge and acquittal on speedy trial grounds, which the trial court granted. The State appealed, and in State v. Bowman, 361 Ga. App. 465 (863 SE2d 180) (2021), the Court of Appeals reversed, holding that a “trial” by an unsworn group of citizens satisfied the requirements of OCGA § 17-7-170. The Georgia Supreme Court granted Bowman’s petition for certiorari and reversed the Court of Appeals’ judgment. View "Bowman v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Evans v. Georgia
Appellant Jonathan Evans challenged his convictions for malice murder and other crimes in connection with the shooting death of Jamirus Wright and the non-fatal shooting of Brandon Martin. Appellant’s only claim on appeal was that he was denied constitutionally effective assistance of counsel at trial due to his attorney’s failure to introduce into evidence footage from the initial responding officers’ body cameras containing statements by them that he claimed would have lent support to his sole defense of justification. However, the Georgia Supreme Court found Appellant did not show that his trial counsel’s failure to introduce such evidence was objectively unreasonable. Thus, he failed to show that his counsel’s performance was constitutionally deficient, which was fatal to his claim. Accordingly, the Court affirmed his convictions. View "Evans v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Camden County v. Sweatt, et al.
Camden County, Georgia appealed a superior court's denial of its “Petition for Writ of Prohibition and Other Relief” concerning an order entered by Camden County Probate Judge Robert Sweatt, Jr., setting a special election for a referendum on whether resolutions authorizing the County’s purchase of land for a rocket launch facility should have been repealed (the “Referendum”). The County claimed the Referendum was not authorized under Subsection (b) (2) of Article IX, Section II, Paragraph I of the Georgia Constitution, which established home rule for counties (the “Home Rule Paragraph”) and that the results of the Referendum are a nullity. As a result, the County argued that the superior court erred in denying its petition for writs of prohibition and mandamus against Judge Sweatt and its petition for a judgment declaring that the Referendum was not authorized under the Constitution. After review, the Georgia Supreme Court disagreed and affirmed the superior court. View "Camden County v. Sweatt, et al." on Justia Law
Rucker v. Georgia
Appellant Anthony Rucker, Jr. was convicted of malice murder and other crimes in connection with a 2014 home invasion and armed robbery which resulted in the death of Tommy Lee Finch, Jr. and serious injuries to Zaccarie Printup. On appeal, Rucker contended the trial court erred in failing to instruct the jury on accomplice corroboration and in denying Rucker’s motion to dismiss the case on constitutional speedy trial grounds. After review, the Georgia Supreme Court found no reversible error and affirmed the trial court. View "Rucker v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Jackson v. Georgia
Appellant Desmond Jackson was convicted of felony murder and other crimes in connection with the 2017 fatal shooting of Heather Smith, the shooting of Quantavious Banks, and the aggravated assault of Kendaishia Jefferies. On appeal, Appellant contended: (1) the evidence was legally insufficient to support his convictions; (2) the trial judge erred by not recusing himself; and (3) that the trial court erred by allowing improper extrinsic evidence to be presented against Appellant at trial. After review of the trial court record, the Georgia Supreme Court found no reversible error and affirmed. View "Jackson v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Huff v. Georgia
Appellant Jazzy Huff was convicted of felony murder and related offenses in connection with the August 2019 shooting death of Zenas Lee Davis. On appeal, Appellant contended: (1) insufficient evidence supported his convictions; (2) the trial court erred in admitting irrelevant, improper, and prejudicial character evidence that Appellant held a firearm “gangster style” prior to firing the gun; (3) the trial court erred in admitting irrelevant, improper, and prejudicial character evidence that Appellant held the firearm the way an armed robber might hold a firearm; (4) he was deprived of an impartial jury because jurors had improper, unsupervised contact with the victim’s family during deliberations; (5) trial counsel was ineffective for failing to object to irrelevant, improper, and prejudicial character evidence; and (6) the cumulative effect of the trial court’s evidentiary errors and trial counsel’s ineffective assistance unfairly prejudiced Appellant and deprived him of his right to due process and a fair trial. After review of the trial court record, the Georgia Supreme Court found no reversible error and affirmed Appellant's convictions. View "Huff v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Allen v. Georgia
After successive jury trials in November 2017 and February 2018, Appellant Broderick Allen was acquitted of participation in criminal street gang activity, but convicted of malice murder and related offenses in connection with the shooting deaths of Antony Jackson and Miguel Hayes. On appeal, Appellant contended the evidence was constitutionally insufficient to support his convictions for the two counts of aggravated assault and two firearm possession charges arising from the November 2017 trial and for the remaining convictions arising from the February 2018 trial. He also contended: the trial court erred by refusing to grant him a new trial under the exercise of its discretion as a “thirteenth juror”; that the trial court erred by denying a motion for mistrial made by Appellant during the November 2017 trial when, according to Appellant, a witness improperly placed his character into evidence; and that the trial court erred during the February 2018 trial by permitting, over Appellant’s objection, the State to improperly bolster the credibility of a State’s witness. Finding the evidence sufficient and no reversible error, the Georgia Supreme Court affirmed. View "Allen v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
McCoy v. Georgia
Appellant Thomas McCoy was convicted of felony murder and other crimes in connection with the 2003 attempted burglary and shooting death of Theodore Barber, as well as theft by receiving of Tony Smith’s SUV. On appeal, Appellant contended in his sole enumeration of error that the evidence was legally insufficient to support his convictions. Finding no error, the Georgia Supreme Court affirmed. View "McCoy v. Georgia" on Justia Law
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Constitutional Law, Criminal Law
Sillah, Murray v. Georgia
After a joint trial, Darnell Sillah and Andrew Murray were convicted of malice murder for the shooting death of Paul Sampleton, Jr., as well as various other crimes. On appeal, Sillah, a juvenile at the time when Sampleton was killed, argued: (1) the evidence was insufficient to support his conviction for criminal gang activity; (2) the trial court erred by admitting his custodial statement; (3) the trial court erred by denying his motion to sever; (4) the trial court failed to consider Sillah’s “youth and attendant characteristics” before sentencing him to life in prison without the possibility of parole (“LWOP”); (5) this sentence violated the Eighth Amendment of the United States Constitution; and (6) the trial court committed other sentencing errors. Murray, proceeding pro se on appeal, appeared to argue the trial court failed to consider the merits of his motion for new trial and that the State failed to present evidence of guilt at the motion for new trial hearing. The Georgia Supreme Court agreed with Sillah that the trial court should have merged his convictions for conspiracy to commit armed robbery and conspiracy to commit burglary, so those convictions were vacated; the Court otherwise affirmed. The Court found record belied Murray’s first claim, and the State had no burden of proof at the hearing, negating the second claim. The Court affirmed Murray's convictions. View "Sillah, Murray v. Georgia" on Justia Law
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Constitutional Law, Criminal Law