Justia Georgia Supreme Court Opinion Summaries

Appellant Raphael Johnson was convicted of the 2013 malice murder of Frederick Burke, the 2013 felony murder of James Cornelius, and other crimes in connection with a shooting incident at a “gambling house,” and the aggravated battery of Ahmed Rayner in connection with another shooting at a restaurant a week later. In his appeal to the Georgia Supreme Court, Appellant contended: (1) the evidence presented at his trial was legally insufficient to support his convictions for the aggravated battery of Rayner; (2) that the trial court’s jury instruction on aggravated assault constituted plain error; and (3) that the trial court abused its discretion by concluding that evidence of another shooting incident that occurred a few hours before the gambling house shootings was admissible as intrinsic evidence. The Supreme Court rejected these contentions and affirmed Appellant’s convictions, except for his conviction for possession of a firearm during the commission of a felony, which was vacated to correct a merger error. View "Johnson v. Georgia" on Justia Law

Darius Dunn appealed his convictions for malice murder and other charges in connection with the 2015 shooting death of Anthony Tavarez. Dunn claimed on appeal that the evidence at trial was insufficient to support his conviction for a violation of the Georgia Street Gang Terrorism and Prevention Act. He also argued the trial court abused its discretion in admitting alleged bad character evidence and allegedly irrelevant and prejudicial video evidence. Finally, Dunn contended he received constitutionally ineffective assistance of counsel because his trial counsel did not seek to redact the State’s exhibits to exclude allegedly irrelevant and prejudicial bad character evidence. Finding no reversible error, the Georgia Supreme Court affirmed. View "Dunn v. Georgia" on Justia Law

A jury found Mustafa Mahdi guilty but mentally ill of the 2014 malice murder of John Quincy III and guilty of possession of a knife during the commission of a felony. Appealing pro se appeal, Mahdi broadly claimed the trial court, as well as his trial and appellate counsel, violated his constitutional rights. After review, the Georgia Supreme Court discerned from these claims that Mahdi was arguing: (1) the trial court violated his due process rights by allowing his trial attorneys to present an insanity defense against his wishes; (2) he received ineffective assistance of trial and motion-for-new trial counsel; and (3) his trial and motion counsel violated his right to conflict-free representation. Finding no reversible error, the Supreme Court affirmed Mahdi's convictions. View "Mahdi v. Georgia" on Justia Law

Tonya Tidwell was convicted by jury of malice murder and aggravated battery in connection with the death of David Guice. On appeal, Tidwell claimed the trial court erred by failing to charge the jury on mutual combat and by failing to suppress evidence obtained during the post-incident search of the crime scene. Finding no reversible error, the Georgia Supreme Court affirmed Tidwell's conviction. View "Tidwell v. Georgia" on Justia Law

Appellant Gerrod Crawford was convicted of felony murder and other crimes related to the 2015 shooting death of Antonio McBride. On appeal, he contended the trial court should have granted his motion for a directed verdict of acquittal and that his trial counsel provided ineffective assistance by failing to make a timely objection to an improper statement made by the prosecutor during her closing argument. Finding no reversible error, the Georgia Supreme Court affirmed. View "Crawford v. Georgia" on Justia Law

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