Justia Georgia Supreme Court Opinion Summaries

Michael Naples was tried by jury and convicted of murder and other crimes in connection with the death of 17-month-old Kaylee Johnson. Investigation revealed the child died from inoperable brain swelling from either having her head slammed against a hard object or having been thrown down a flight of stairs. Naples appealed, contending that the trial court erred when it admitted “other acts” evidence under OCGA 24-4-404 (b) (“Rule 404 (b)”) and that he was denied the effective assistance of counsel. Finding no reversible error, the Georgia Supreme Court affirmed. View "Naples v. Georgia" on Justia Law

Otheron Walker was convicted by jury of malice murder in connection with the beating death of his ten-month-old daughter, Daijah White. On appeal, Walker contended the evidence was insufficient, that the jury was improperly charged, and that trial counsel was ineffective. Finding no reversible error, the Georgia Supreme Court affirmed. View "Walker v. Georgia" on Justia Law

Daniel Thomas was convicted by jury for malice murder in connection with the shooting death of Elliott Mizell. Thomas argued on appeal that the evidence was insufficient to support his conviction; that the trial court erred by admitting an involuntary custodial statement; and that trial counsel was ineffective in two ways. The Georgia Supreme Court affirmed, finding the evidence was sufficient to support Thomas’s convictions; the custodial statement was not involuntary; and Thomas failed to show that his trial counsel was deficient as to one ineffective assistance of counsel claim, and failed to show prejudice as to the other. View "Thomas v. Georgia" on Justia Law

Antiwan Lane was convicted by jury of malice murder and other charges for procuring the murder of Ivan Perez. The trial court granted Lane a new trial based on a host of grounds, including evidentiary errors and ineffective assistance of counsel. The State appealed, arguing that none of the claimed errors by counsel or the trial court resulted in sufficient prejudice or harm to require reversal. Given the large number of errors at issue, the Georgia Supreme Court first reconsidered and overruled its prior precedent that precluded full consideration of the cumulative effect of multiple errors at trial. The Court then concluded counsel was ineffective in at least two respects and the trial court made at least one key evidentiary error in overruling a defense objection. Lastly, given the combined prejudicial effect of multiple errors by counsel and the trial court, the Court affirmed the grant of a new trial. View "Georgia v. Lane" on Justia Law

Tony Mitchell was convicted by jury of malice murder and other crimes in connection with the death of Randy Lewis. On appeal, Mitchell contended his trial counsel rendered ineffective assistance because she failed to competently execute her chosen strategy of discrediting the jailhouse informant who testified that Mitchell had confessed to having killed Lewis. Finding no reversible error, the Georgia Supreme Court affirmed. View "Mitchell v. Georgia" on Justia Law

Arheem DeLoach was convicted by jury on two counts of malice murder and other crimes in connection with the deaths of Rashad Biggins and Jamell Law. In Case No. S19A1299, DeLoach contended the trial court erred in denying his motion for a new trial with respect to the crimes committed against Law, asserting that his trial counsel was ineffective in two ways: (1) counsel failed to move to sever the counts involving Law from those involving Biggins, and (2) counsel failed to object or to move for a mistrial when the trial judge mentioned the appellate process before giving the final jury charge. In Case No. S19X1300, the State cross-appealed, contending the trial court erred in granting DeLoach a new trial with respect to the crimes committed against Biggins. The State argued that the trial court’s basis for granting a new trial, that the prosecutor knowingly failed to correct material, false testimony from a key witness, was is unsupported by the record. The Georgia Supreme Court concurred with the reasons given below in Division 2, affirmed that portion of the trial court’s judgment. As set forth in Division 3, the Supreme Court reversed that portion of the trial court’s judgment because the record did not support the trial court’s finding that the false testimony was material. View "DeLoach v. Georgia" on Justia Law

Lazarus White was convicted by jury of malice murder and another crime in connection with the 2012 stabbing death of Terry Bell. He appealed, arguing the trial court erred in excluding testimony regarding Bell’s alleged act of violence against a third party and three instances of ineffective assistance of trial counsel. Finding no reversible error, the Georgia Supreme Court affirmed. View "White v. Georgia" on Justia Law

City of Atlanta (“the City”) and the Atlanta Independent School System (“APS”) were involved in a dispute over the City’s annexing property in Fulton County, while it expressly prohibiting the co-expansion of APS’s territory. The Georgia Supreme Court granted the City’s application for interlocutory appeal challenging the trial court’s denial of its motion to dismiss. The Court concluded this matter did not amount to an actual, justiciable controversy; consequently, it vacated the trial court’s order and remanded for this case to be dismissed by the trial court. “These parties have appeared before this Court numerous times, and the instant dispute is part of a larger, ongoing disagreement between the City and APS. … Mere disagreement about the ‘abstract meaning or validity of a statute [or ordinance]’ does not constitute an actual controversy within the meaning of the Declaratory Judgment Act. … APS has failed to establish the existence of an actual controversy, for purposes of declaratory relief, because it has failed to demonstrate that a ruling in its favor would have any immediate legal consequence.” View "City of Atlanta v. Atlanta Indep. Sch. Sys." on Justia Law

Aaron Howell was convicted by jury of malice murder, aggravated assault, and aggravated battery in connection with the beating death of Paul Guerrant. Howell argued on appeal that the evidence presented at his trial was legally insufficient to support his convictions and that the trial court erred by admitting other-act evidence under OCGA 24-4-404 (b). After review, the Georgia Supreme Court affirmed Howell’s murder conviction, although it vacated his convictions for aggravated assault and aggravated battery to correct merger errors. View "Howell v. Georgia" on Justia Law

Sandy Mitchell, Jr., was convicted by jury of malice murder and other crimes in connection with the shooting death of Byron Brown. On appeal, Mitchell argued his trial counsel was constitutionally ineffective for failing to object to certain trial testimony from a detective in this case on the grounds that it was improper expert opinion, and that other testimony offered by the same detective was admitted in violation of Brady v. Maryland, 373 U.S. 83 (1963). Mitchell also contended the trial court erred in permitting the detective to testify about the alleged Brady violation evidence and in admitting a particular autopsy photograph into evidence. Finding no reversible error, the Georgia Supreme Court affirmed. View "Mitchell v. Georgia" on Justia Law