Justia Georgia Supreme Court Opinion Summaries

Michael Williams was indicted on two counts of felony murder, burglary in the first degree, aggravated assault, possession of a firearm during the commission of a felony, and possession of a firearm by a convicted felon. The State filed notice of its intent to introduce evidence of other wrongs, crimes, or acts pursuant to OCGA § 24-4-404 (b) (“Rule 404 (b)”). The State specified that the other-acts evidence would be offered as evidence of Williams’s motive and intent in killing Sandra Fields and would include Williams’s January 2017 arrest for family violence battery against another woman, Sommer Sheffield. After a hearing, the trial court ruled that evidence of the 2017 battery was inadmissible, on the basis that the probative value of the evidence was substantially outweighed by undue prejudice. The State appealed that ruling, contending the trial court misapplied the applicable balancing test and abused its discretion in excluding evidence of Williams’s prior act of domestic violence. The Georgia Supreme Court concurred with the State, vacated the trial court’s ruling and remanded for the trial court to reconsider the matter under the proper framework. View "Georgia v. Williams" on Justia Law

Nicholas Bacon 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 his 64-year-old mother, Montez Bacon. On appeal, Bacon alleged that the trial court abused its discretion when it excluded the testimony of the defense’s expert witness and that he received constitutionally ineffective assistance of counsel. Finding no reversible error, the Georgia Supreme Court affirmed. View "Bacon v. Georgia" on Justia Law

Michael Perrault was convicted by jury of malice murder and simple battery, family violence of his wife, Amanda Perrault. On appeal, Perrault argued: (1) the evidence was not sufficient to support his convictions; (2) the trial court erred in refusing to transfer the case to a different venue; and (3) he was entitled to a new trial due to cumulative error. Finding no reversible error, the Georgia Supreme Court affirmed. View "Perrault v. Georgia" on Justia Law

Appellant Sasha McCalop was convicted of malice murder in connection with the stabbing death of Michael Martin, her boyfriend of three years. On appeal, McCalop contended: (1) the trial court erred in allowing the State’s expert to comment on McCalop’s state of mind; (2) the trial court erred in allowing the State’s expert to testify because he had never testified in Georgia before and was not familiar with Georgia law on battered person syndrome (“BPS”); (3) the trial court erred in allowing the State’s expert to testify that BPS had no scientific basis and that trial courts were wrong in providing jury instructions on BPS; (4) the State committed prosecutorial misconduct by arguing to the jury that BPS was not a recognized diagnosis or defense; and (5) the trial court erred in ruling that a defense witness “opened the door” to presenting evidence of McCalop’s bad character. Finding no error, the Georgia Supreme Court affirmed. View "McCalop v. Georgia" on Justia Law

Following a joint trial with co-defendants Darnell Sillah and Andrew Murray, Tavaughn Saylor was convicted of malice murder for the 2012 shooting death of Paul Sampleton, Jr., as well as various other crimes. On appeal, Saylor arguedL (1) the evidence was insufficient to support his convictions for aggravated assault of Stevo Hrnjak and criminal damage to Hrnjak’s property; (2) the trial court erred by denying his motion to sever; (3) the trial court erred in striking several jurors; and (4) his conviction for a violation of the Street Gang Terrorism and Prevention Act merged. The Georgia Supreme Court found none of these claims had merit, and affirmed. View "Saylor v. Georgia" on Justia Law

Torres Boles appealed his convictions for felony murder and other charges in connection with the death of his three-year-old daughter, Andraia Boles. He argued on appeal that the evidence was insufficient to support his convictions and that the trial court erred in admitting into evidence statements he made to “Ms. Middleton,” a protective services investigator and case manager with the Georgia Department of Family and Children Services (“DFCS”) and to Renee Sylvester, a private-sector counselor hired by DFCS in connection with the agency’s investigation into placing Boles’s other daughter into foster care. Boles argued that the two DFCS investigators were acting as agents of law enforcement when they interviewed him and their failure to give him warnings under Miranda v. Arizona, 384 U.S. 436 (1966), rendered his statements inadmissible. After review, the Georgia Supreme Court concluded the evidence was sufficient to support Boles’s convictions, there was no error in the admission of Boles’s statement to Middleton, and any error in the admission of his statement to Sylvester was harmless, as such evidence was cumulative of other, properly admitted evidence. Accordingly, the convictions were affirmed. View "Boles v. Georgia" on Justia Law

Appellant Tyree Ingram was convicted of felony murder and other crimes in connection with the fatal shooting of LaMarcus Brown during the early morning hours of September 13, 2019. On appeal, Ingram contended his trial counsel rendered ineffective assistance by: (1) failing to object to good character evidence of the victim; (2) failing to object to and redact the portion of Ingram’s recorded statement to law enforcement officers where he mentioned his juvenile criminal history; and (3) failing to object to the classification of Ingram’s first offender sentence as a “conviction” when it was tendered into evidence by the State. Ingram also contended that the cumulative effect of trial counsel’s ineffectiveness entitled him to a new trial. Finding no ineffective assistance of counsel, the Georgia Supreme Court affirmed. View "Ingram v. Georgia" on Justia Law

Derrick Session challenged his convictions for failing to register as a sex offender in Georgia based on a conviction he received in Louisiana. He argued: (1) the evidence was insufficient to support his Georgia convictions; (2) the Georgia registration statute as applied to him violated his federal rights to travel and equal protection; and (3) he raised a facial challenge to the registration statute under the Georgia constitutional prohibition against legislation regarding the social status of citizens. After thorough consideration, the Georgia Supreme Court rejected those arguments and affirmed. View "Session v. Georgia" on Justia Law

Appellant Anthony Martin challenged his 2015 convictions for felony murder and a firearm offense in connection with the shooting death of Marlon Underwood. Appellant’s only enumeration of error was that the evidence presented at trial was legally insufficient to support his convictions as a matter of constitutional due process and Georgia statutory law. When properly viewed in the light most favorable to the jury’s verdicts, the Georgia Supreme Court found the evidence was sufficient to support Appellant’s convictions. Accordingly, the convictions were affirmed. View "Martin v. Georgia" on Justia Law

Evins Vontravis Harris was convicted by jury of felony murder and other crimes in connection with the 2018 shooting death of Darius Roberts. On appeal, Harris argued the trial court erred in denying him immunity from prosecution and abused its discretion by admitting an in-life photograph of Darius at trial. Finding no reversible error, the Georgia Supreme Court affirmed Harris' convictions. View "Harris v. Georgia" on Justia Law