Justia Georgia Supreme Court Opinion Summaries

The Georgia Supreme Court granted certiorari to reconsider one of its holdings in Allstate Insurance Co. v. Klein, 422 SE2d 863 (1992). In Klein, the Court held that Georgia courts could exercise general personal jurisdiction over any out-of-state corporation that was “authorized to do or transact business in this state at the time a claim arises.” Although Klein’s general-jurisdiction holding was in tension with a recent line of United States Supreme Court cases addressing when state courts may exercise general personal jurisdiction over out-of-state corporations in a manner that accords with the due process requirements of the United States Constitution, the Georgia Court held Klein did not violate federal due process under Pennsylvania Fire Insurance Co. of Philadelphia v. Gold Issue Mining & Milling Co., 243 U. S. 93 (1917), a decision that the U.S. Supreme Court has not overruled. "Thus, we are not required to overrule Klein as a matter of binding federal constitutional law. We also decline to overrule Klein as a matter of statutory interpretation. Therefore, we affirm the Court of Appeals’ decision, which followed Klein." View "Cooper Tire & Rubber Co. v. McCall" on Justia Law

Leon Williams was convicted by jury of malice murder, terroristic threats, and three counts of cruelty to children in connection with the drowning death of his ten-year-old autistic and special needs son, Kentae. Williams contended the evidence presented at trial was insufficient to support his convictions. He also argued that one of his three convictions for cruelty to children should have been vacated because it merged with his malice murder conviction. Finding no reversible error, the Georgia Supreme Court affirmed. View "Williams v. Georgia" on Justia Law

Appellant Carl Logan challenged his 2017 convictions for malice murder and possession of a knife during the commission of a crime in connection with the 2012 stabbing and beating death of Anthony Olivet. Appellant’s sole enumeration of error was that the trial court violated his constitutional rights to confront his accusers by preventing him from playing for the jury certain audio-recorded statements that a prosecution witness made to law enforcement officers to impeach the witness on cross-examination. The Georgia Supreme Court determined the record did not support this claim. Accordingly, the Court affirmed the trial court. View "Logan v. Georgia" on Justia Law

Appellant Brian Lewis was convicted by jury of malice murder and concealing the death of another in connection with the beating death of Ronald Redding. Appellant argued: the evidence presented at his trial was insufficient to support his murder conviction; the trial court erred by failing to charge the jury on voluntary manslaughter; he was denied constitutionally effective assistance of counsel; and that the cumulative effect of trial counsel’s errors prejudiced him. Finding no reversible error, the Georgia Supreme Court affirmed. View "Lewis v. Georgia" on Justia Law

The Georgia Supreme Court granted Corey Nelson's application for interlocutory appeal of a trial court's denial of his motion to suppress evidence. At issue was evidence extracted from his cell phone and other electronic devices pursuant to search warrants. Nelson argued that the delay of more than two years between the date on which the electronic devices were seized pursuant to a search warrant for his residence, and the dates on which the devices were examined pursuant to subsequent search warrants for their contents, violated his Fourth Amendment rights. The Supreme Court found the evidence challenged here was extracted days after warrants issued in 2020. The only challenge Nelson offered to this evidence was the long delay between the 2017 seizure of the devices and the 2020 issuance of the warrants. The Court found his possessory interest in the devices was greatly diminished by the combination of his incarceration for the entire period of the delay and his failure to request the devices’ return. Thus, the Court concluded the trial court did not err in denying the motion to suppress. View "Nelson v. Georgia" on Justia Law

Bryant Willerson was convicted of murder in connection with the 2011 beating death of William McClain. On appeal, Willerson contended the evidence presented at his trial was insufficient to find him guilty beyond a reasonable doubt of the crime of which he was convicted. He also argued his trial counsel rendered constitutionally ineffective assistance for failing to properly impeach a witness. Finding no reversible error, the Georgia Supreme Court affirmed. View "Willerson v. Georgia" on Justia Law

Nathaniel Baker was convicted by jury of felony murder and other offenses in connection with crimes committed against Craigory Burch, Jr., Jasmine Hendricks, and C.B., a minor child. On appeal, Baker argued the evidence presented at trial was insufficient to support his convictions and that the trial court erred by allowing the State to present evidence of criminal gang activity. Finding no reversible error, the Georgia Supreme Court affirmed. View "Baker v. Georgia" on Justia Law

Appellant Quintavious Walker was convicted of the murder of Jaquille Thomas and Angelique Bowman. In his one issue raised on appeal, he contended the trial court erred by admitting into evidence at his trial incriminating statements that he made after he allegedly invoked his Fifth Amendment right to remain silent during a custodial interview with the police. The Georgia Supreme Court found Appellant’s purported invocations were not unambiguous and unequivocal and not clearly erroneous. Therefore, the trial court did not commit plain error by admitting the statements. View "Walker v. Georgia" on Justia Law

Dion Sims appealed after a jury convicted him of malice murder and other crimes in connection with the 2001 shooting death of Alan Watson. On appeal, Sims argued: (1) the evidence presented at trial was insufficient to support his conviction; (2) the State failed to prove venue; and (3) his trial counsel provided constitutionally ineffective assistance by failing to file a plea in bar with respect to two counts of the indictment. After review, the Georgia Supreme Court determined Sims’ contentions lacked merit and affirmed his convictions. View "Sims v. Georgia" on Justia Law

In 2013, Alexander Woods III was convicted by jury of five counts of malice murder and given five consecutive life sentences in connection with the 2004 shooting deaths of four members of the Resendez family and their housekeeper. Woods’ motion for new trial was denied, and he appealed, raising nine alleged instances of ineffective assistance of trial counsel. After review of the record, the Georgia Supreme Court vacated the trial court’s order denying Woods’ motion for new trial, and remanded the case for the trial court to rule in the first instance on the question of deficiency of trial counsel and related evidentiary issues. View "Woods v. Georgia" on Justia Law