Justia Georgia Supreme Court Opinion Summaries

Tevision Troy appealed his convictions for the 2016 murder of Tony Saffo and a firearm offense. Troy argued only that the trial court erred in admitting evidence that he committed an aggravated assault in 1998 with the same gun that was used to kill Saffo. He contended admitting this evidence violated OCGA sections 24-4-404 (b) (“Rule 404 (b)”) and 24-4-403 (“Rule 403”). But the Georgia Supreme Court determined it did not need to reach the merits of Troy’s contentions, as the evidence’s admission was harmless even if erroneous. View "Troy v. Georgia" on Justia Law

The State appealed the grant of habeas relief to Aaron Houston, who pleaded guilty to three misdemeanor DUI counts. The habeas court vacated the convictions entered on those pleas on grounds that the pleas were tendered without the assistance of counsel and without Houston being advised of his right to counsel, and that Houston did not knowingly and voluntarily waive his right to counsel. The State argued to the Georgia Supreme Court that the habeas court erred because Houston did not produce sufficient evidence that his waiver of counsel was not knowing and voluntary. Because the habeas court did not clearly err in concluding that Houston was not advised of his right to counsel at the plea hearing, thereby precluding an express waiver of that right, the Supreme Court affirmed. View "Georgia v. Houston" on Justia Law

Miguel Angel Garcia-Martinez was convicted of malice murder, four counts of aggravated assault, and four counts of possession of a firearm during the commission of a felony in connection with the 2018 shooting death of his friend and former roommate, Daniel Antonio-Lopez, and the aggravated assaults of Antonio-Lopez, Juan Carlos Mondragon, Saul Roman-Pintado, and Francisco Lopez. The trial court denied Garcia-Martinez’s motion for new trial, and he appealed, using as his sole enumeration of error the sufficiency of the evidence to support his convictions. Finding the evidence sufficient, the Georgia Supreme Court affirmed. View "Garcia-Martinez v. Georgia" on Justia Law

Rebecca Schoicket was granted an out-of-time appeal to appeal the judgment of conviction entered on her guilty plea. In addition to challenging her sentence on one count, she argued the out-of-time appeal she was granted meant that the trial court should have granted her motion for leave to file an otherwise untimely motion to withdraw her guilty plea. Schoicket argued that Collier v. Georgia, 834 SE2d 769 (2019), recognized that it would be a “logical extension” of Georgia case law to permit the filing of such a motion, because the Georgia Supreme Court has stated that the grant of an out-of-time appeal started the post-conviction process “anew.” The Supreme Court determined Schoicket was correct in that appraisal of Georgia case law, but the Court declined to extend it to afford her the relief she sought. "Allowing such a grant to then permit the movant to file a motion to withdraw a guilty plea would be an unwarranted windfall with potentially profound consequences for our criminal justice system." Accordingly, the Court affirmed the trial court's denials of Schoicket's motion for leave to pursue such relief. However, because the Court agreed with Schoicket that the sentencing court erred in sentencing as to one count, that count was vacated and remanded for resentencing. View "Schoicket v. Georgia" on Justia Law

Jabarri Ash was convicted by jury of malice murder and other crimes arising from the shooting death of Mario Shaw. On appeal, Ash argued the trial court erred by admitting evidence of his prior convictions pursuant to OCGA 24-4-404 (b); that the trial court erred by admitting evidence of certain statements made by Shaw pursuant to OCGA 24-8- 807; that the State improperly destroyed exculpatory evidence; that the trial court plainly erred in its instructions to the jury; and that the cumulative harm of these errors affected the trial’s outcome such that he should receive a new trial. The Georgia Supreme Court concluded there was no reversible error, and affirmed. View "Ash v. Georgia" on Justia Law

Appellant Lil’Che Stafford was found guilty by jury of felony murder and first-degree burglary in connection with the death of Jose Greer. On appeal, Appellant argued: (1) evidence of an earlier burglary and armed robbery was improperly admitted at trial; (2) a testifying detective inappropriately opined that Appellant was involved in an additional prior robbery; (3) trial counsel was ineffective for failing to request a jury instruction on intervening or unforeseen cause of death; and (4) the detective’s testimony regarding the custodial statements of a co-conspirator was improperly admitted because it was inadmissible hearsay and trial counsel was ineffective for failing to object to its admission based on the Confrontation Clause. The Georgia Supreme Court concluded there was no reversible error, and affirmed. View "Stafford v. Georgia" on Justia Law

This case arose from Rockdale County, Georgia's denial of an application for a permit to build a QuikTrip on property owned by William Corey and U.S. Enterprises, Inc. (the “Owners”), on the ground that the proposed facility was a “truck stop,” which was a prohibited use under the County’s Unified Development Ordinance (“UDO”). After the County’s Board of Adjustment affirmed the denial of the permit, the Owners filed a petition to the Rockdale County Superior Court seeking, among other things, certiorari under OCGA 5-4-1 et seq. The superior court sustained the petition for certiorari, rejecting the County’s argument that the Owners’ lawsuit was barred by res judicata and reversing the Board’s decision on the ground that the UDO’s applicable definition of a “truck stop” was unconstitutionally vague and therefore violated due process under the Georgia Constitution. The Georgia Supreme Court granted County’s application for a discretionary appeal, and the Owners then cross-appealed. The Supreme Court affirmed the superior court’s rejection of the County’s res judicata argument, reversed the part of the superior court’s judgment ruling that the “truck stop” definition was unconstitutionally vague, and remanded the case for further proceedings. The Court's holding made it unnecessary to address the Owners’ cross-appeal, which was accordingly dismissed as moot. View "Rockdale County et al.. v. U. S. Enterprises, Inc." on Justia Law

Harold George was convicted by jury of two counts of child molestation and related offenses. He appealed to the Georgia Court of Appeals, which affirmed his convictions in an unpublished opinion. In addressing one of George’s four enumerations of error, the Court of Appeals rejected his argument that the search of his home exceeded the scope of the relevant search warrant, agreeing with the trial court that “[t]he police officers were not compelled to overlook relevant evidence simply because it was not specifically listed in the search warrant.” Both the trial court and the Court of Appeals cited Walsh v. Georgia, 512 SE2d 408 (1999), for this proposition. The Georgia Supreme Court determined both the appellate and trial courts did not use the correct legal standard for a constitutional Fourth Amendment challenge to the seizure of evidence beyond the scope of a search warrant. The Court therefore vacated the relevant part of the Court of Appeals’ judgment and remand this case for further proceedings. View "George v. Georgia" on Justia Law

Keontay Miller appealed his convictions for malice murder and other crimes arising out of the shooting death of Tellis Fort. Miller contended the evidence presented at his trial was insufficient as a matter of constitutional due process to support the verdict, and that there were direct and irreconcilable conflicts in the evidence and contradictions between the testimonies of witnesses at trial, which required a new trial. The Georgia Supreme Court found no merit to these contentions, though it did find the trial court committed two merger errors at sentencing. Judgment was affirmed in part, vacated in part, and remanded for resentencing. View "Miller v. Georgia" on Justia Law

Steven Jones appealed his convictions for malice murder, aggravated assault, and other offenses arising in connection with the death of Quincey Denton and the assault of Kenneth Studivant. On appeal, Jones argued the evidence was insufficient to support his convictions, and that the trial court erred in denying his motion for mistrial after the admission of allegedly improper character evidence during the State’s case. Finding no merit to these contentions, the Georgia Supreme Court affirmed. View "Jones v. Georgia" on Justia Law