Justia Georgia Supreme Court Opinion Summaries

In this case, the appellant was convicted of felony murder in connection with the death of a man who had allowed him to stay in his home. The evidence at trial showed that the appellant had been living with the victim and his sister for about a year. On the day of the incident, a family member brought the appellant to the victim’s home, where only the victim was present. Later that day, the victim’s family received troubling calls from the appellant, who reported that he and the victim had fought and that the victim was unresponsive. Law enforcement arrived to find the victim deceased from blunt force trauma and strangulation, with the appellant present at the scene. The appellant’s custodial interview included admissions that he struck the victim multiple times following a dispute and that he attempted to revive him.A Columbia County grand jury indicted the appellant on multiple counts, including malice murder and felony murder predicated on aggravated assault. At trial, the jury found him guilty of two counts of felony murder but could not reach a verdict on the malice murder count, which resulted in a mistrial for that count. The appellant was sentenced to life without parole. He filed a motion for a new trial, which was denied by the Superior Court of Columbia County after an evidentiary hearing.The Supreme Court of Georgia reviewed the appellant’s claims, including challenges to the sufficiency of the evidence, the admission of his custodial statement, and the admission of autopsy photographs. The court held that the evidence was constitutionally sufficient to support the conviction, that the appellant’s custodial statements were properly admitted because he reinitiated communication with officers after invoking his right to counsel, and that the autopsy photographs were admissible and not unfairly prejudicial. The Supreme Court of Georgia affirmed the judgment. View "BURNS v. THE STATE" on Justia Law

In this case, the defendant was convicted of felony murder and other offenses stemming from the shooting death of an individual in a parking garage following a dice game. The prosecution’s evidence indicated that the victim and another person were targeted for robbery by a group, including the defendant, after a dispute over gambling losses. Testimony from a co-defendant described the planning and execution of the crime, corroborated by cell phone records, surveillance footage, and forensic evidence. The defendant admitted to being present at the scene but denied active participation in the robbery.The case was initially indicted by a Fulton County grand jury, charging the defendant and four co-defendants with multiple counts. Two co-defendants pleaded guilty, while the defendant and two others were tried jointly before a jury in the Superior Court of Fulton County. The defendant was acquitted of malice murder but convicted on the remaining counts. He was sentenced to life in prison for felony murder, plus additional concurrent and consecutive terms for other offenses. The defendant filed a motion for a new trial, which was denied after an evidentiary hearing.On appeal, the Supreme Court of Georgia reviewed several claims, including sufficiency of the evidence, alleged due process violations regarding co-defendants’ plea deals, the accuracy of jury instructions, and the denial of severance. The Court held that the evidence was sufficient to support the convictions, found no due process violations in the prosecution’s handling of co-defendants’ plea deals, concluded that the jury instructions were proper when viewed in totality, and determined that severance was not required. The Supreme Court of Georgia affirmed the defendant’s convictions. View "WELLS v. THE STATE" on Justia Law

On September 13, 2019, police in DeKalb County, Georgia, responded to reports of a van on fire. After extinguishing the blaze, they discovered the burned body of Tiffany Valkoun inside. Investigation revealed that Valkoun died from a gunshot wound to the back of the head, and that her body was burned post-mortem. Evidence showed that Valkoun had been with Antisa Columbus and Eureon Phillips shortly before her death. Columbus, who was dating Phillips at the time, testified that an argument occurred, during which Phillips struck Valkoun with a gun and fatally shot her. Phillips and others then conspired to dispose of Valkoun’s body by setting the van on fire. Key evidence included witness testimony, cell phone location data, and forensic analysis.A DeKalb County grand jury indicted Phillips on multiple charges, including malice murder, felony murder, aggravated assault, arson, and related firearms offenses. At his separate trial, the jury convicted Phillips of felony murder and other crimes, but acquitted him of malice murder. The Superior Court of DeKalb County sentenced Phillips to life without parole for felony murder and concurrent or consecutive terms for the other offenses. Phillips filed a motion for a new trial, which was denied by the trial court.The Supreme Court of Georgia reviewed Phillips’s appeal. He challenged the sufficiency of the evidence, the denial of his motion for mistrial after witness testimony regarding credibility, and the trial court’s restriction on playing witness statements in full. The Supreme Court held that the evidence was sufficient to support the verdict, found no abuse of discretion in denying the mistrial given the curative instructions, and ruled that the trial court did not err in admitting only relevant portions of prior witness statements. The court affirmed Phillips’s convictions and sentences. View "PHILLIPS v. THE STATE" on Justia Law

On the evening of April 2, 2017, an altercation occurred between two men, each affiliated with rival gangs in Macon, Georgia, but who had known each other for years. The altercation resulted in one of the men sustaining an arm injury. The next day, the two encountered each other at a convenience store known as a gang hangout. Surveillance footage captured the two walking and talking across the parking lot, appearing calm, until they reached a dumpster. After a brief interaction with a car’s occupants, one man shot the other in the back of the head and fled. The shooter later spoke with police, initially denying involvement but ultimately admitting at trial that he shot the victim, claiming self-defense out of fear for his life.Following indictment on several charges, including malice murder, a Bibb County jury convicted the shooter of malice murder, felony murder, and aggravated assault, but acquitted him of gang-related charges. The trial court merged the convictions for sentencing, and imposed life without parole. After the conviction, the defendant sought a new trial, arguing that the bailiffs were unsworn, that his trial counsel was ineffective for not objecting to certain evidence, and that the court erred by refusing a voluntary manslaughter instruction. The Superior Court of Bibb County denied his motion, and the defendant timely appealed.The Supreme Court of Georgia reviewed the appeal. The Court held that the defendant failed to rebut the presumption that the bailiffs had been properly sworn. It found no deficiency in trial counsel’s failure to object to autopsy photographs or to the admission of an older conviction, as such objections would have been meritless or reasonable trial strategy. Finally, the Court held that the evidence did not support a voluntary manslaughter instruction, as the defendant’s own testimony indicated he acted in self-defense rather than in the heat of passion. The Court affirmed the judgment. View "STAPLETON v. THE STATE" on Justia Law

The case involves a fatal shooting that occurred early in the morning of October 1, 2016. The victim, Bernie Givens, was shot outside his home, after which his girlfriend called 911. Evidence collected at the scene included firearms, shell casings, drugs, and money. Testimony at trial established that Givens had won a significant amount of money at a block party earlier that evening, and several witnesses described the defendant, John Lorenzo Dickerson, behaving suspiciously around Givens and expressing a need for money. One eyewitness identified Dickerson as the shooter, and multiple witnesses described Dickerson’s actions after the crime, including wiping down a gun and leaving for New Jersey.The Superior Court of Emanuel County held a jury trial at which Dickerson was acquitted of malice murder and one firearm charge but convicted on counts including felony murder, aggravated assault, attempted armed robbery, and additional firearm offenses. Dickerson was sentenced to life without parole plus additional consecutive terms. He filed a motion for a new trial, which was denied after hearings. He then appealed.The Supreme Court of Georgia reviewed the case. Dickerson challenged the trial court’s admission of prior bad act evidence, the giving of jury instructions on flight and witness intimidation, and alleged ineffective assistance of counsel. The Supreme Court assumed, without deciding, that the admission of prior act evidence was erroneous but found any error harmless due to overwhelming evidence of guilt and proper limiting instructions. The Court also held that Dickerson’s counsel was not constitutionally ineffective, and any assumed errors did not cumulatively prejudice his defense. The Supreme Court of Georgia affirmed the convictions. View "DICKERSON v. THE STATE" on Justia Law

Marco Franklin was charged with several offenses in connection with the shooting death of Jamarco Royal in DeKalb County, Georgia. On the evening of December 3, 2018, Royal was shot after answering a knock at the door while at a relative’s apartment. Witnesses observed two individuals fleeing the scene, and officers later discovered a Motorola phone near the apartment, which was linked to Franklin through social media records and other evidence. Additional investigative steps led police to Franklin’s mother’s home, where an iPhone associated with Franklin was seized and searched pursuant to a warrant. The contents of both phones, along with Franklin’s own statements to police, connected him to the planning and commission of a robbery that resulted in Royal’s death.Franklin was indicted in the Superior Court of DeKalb County on charges including malice murder, felony murder, armed robbery, aggravated assault, and possession of a firearm during the commission of a felony. His first trial ended in a mistrial. At a retrial, a jury found Franklin guilty of all charges except malice murder. The trial court sentenced him to life in prison with the possibility of parole for felony murder and a consecutive five-year term for possession of a firearm. After sentencing, Franklin filed a motion for new trial, which was denied.On appeal to the Supreme Court of Georgia, Franklin argued that his trial counsel was constitutionally ineffective for failing to move to suppress evidence from the warrantless search of the Motorola phone and the search of the iPhone pursuant to a warrant. The Supreme Court of Georgia held that counsel was not ineffective, as Franklin had abandoned the Motorola phone for Fourth Amendment purposes and a motion to suppress would not likely have succeeded. The Court also found that, under precedent existing at the time of trial, a challenge to the particularity of the iPhone warrant would not have clearly succeeded. The judgment was affirmed. View "FRANKLIN v. THE STATE" on Justia Law

In the early morning hours of April 15, 2019, Qamar Williams shot and killed Calvin Chappell at a residence in Decatur, Georgia. Williams and Chappell, who were friends, had spent the evening with others at several nightclubs before returning to the house. Security footage captured Williams shooting Chappell multiple times while Chappell slept. Witnesses at the scene did not observe Williams to be under the influence of drugs, and Williams did not testify at trial but did testify at the motion for new trial hearing.The Superior Court of DeKalb County conducted the trial, where a jury found Williams guilty of malice murder, felony murder predicated on aggravated assault, felony murder predicated on possession of a firearm by a convicted felon, aggravated assault, possession of a firearm by a convicted felon, and possession of a firearm during the commission of a felony. The trial court sentenced Williams to life in prison without parole plus additional consecutive sentences. Williams filed a timely motion for new trial, which he amended to include claims of newly discovered evidence supporting a defense of involuntary intoxication. The trial court denied the amended motion after an evidentiary hearing, finding that the evidence could have been discovered earlier with due diligence, was not credible, and was not material enough to likely affect the verdict.On appeal, the Supreme Court of Georgia reviewed Williams’s claims, including errors regarding newly discovered evidence, the failure to instruct the jury on involuntary intoxication, and ineffective assistance of counsel. The Court held that Williams failed to meet the requirements for a new trial based on newly discovered evidence and found no error in the jury instructions since there was insufficient evidence of involuntary intoxication. Further, Williams did not demonstrate prejudice resulting from counsel’s alleged deficiencies. The Supreme Court of Georgia affirmed the convictions. View "WILLIAMS v. THE STATE" on Justia Law

The case involves a defendant who, along with two co-indictees, was charged with multiple offenses—including malice murder, felony murder, armed robbery, aggravated battery, and aggravated assault—stemming from the beating death of one victim and the assault of another. The crimes occurred over two days in December 2018. The defendant’s trial began in April 2023, but after a co-indictee testified against him and another was set to do so, the defendant chose to enter a non-negotiated guilty plea to all counts. The court sentenced him to life with the possibility of parole for malice murder and armed robbery, with additional concurrent terms for other offenses.After sentencing, the defendant obtained new counsel and moved to withdraw his guilty plea, arguing that he had not knowingly or voluntarily waived his rights as required, and that his plea counsel was constitutionally ineffective by coercing him into the plea. At the evidentiary hearing before the Superior Court of Gwinnett County, both the defendant and his plea counsel testified. The plea counsel asserted he had advised the defendant of the overwhelming evidence and the risks of proceeding to trial but denied using threats or coercion. The court found that the defendant was fully informed of his rights, that the plea was entered voluntarily, and that plea counsel’s representation was not deficient.On appeal, the Supreme Court of Georgia reviewed the denial of the motion to withdraw the guilty plea. The court held that the plea was entered knowingly, voluntarily, and intelligently, and that the record supported the trial court’s findings. It also determined that plea counsel’s conduct did not constitute ineffective assistance. However, the Supreme Court identified sentencing errors regarding the merger of certain counts and vacated the convictions and sentences on those counts, remanding for correction. Otherwise, the judgment was affirmed. View "WILLIAMS v. THE STATE" on Justia Law

A father was charged in connection with the death of his seven-month-old son, who had been left in his care. On the evening of the incident, the child’s mother was informed that the baby was choking and was taken to a hospital. Medical professionals discovered severe brain injuries, which ultimately led to the child’s death after life support was removed. Expert testimony at trial indicated the injuries were consistent with abusive head trauma rather than accidental choking or gentle shaking, contradicting the father's account. The defense presented alternative expert opinions suggesting the injuries could have resulted from emergency medical treatment or were consistent with the father’s version of events.A Muscogee County grand jury indicted the father for felony murder and cruelty to children in the first degree. Following a jury trial, he was convicted on both counts, with the cruelty to children conviction merged for sentencing. He received a life sentence without parole for murder. The trial court denied his amended motion for a new trial after a hearing, finding the evidence supported the jury’s verdict and that the verdict was not contrary to justice or equity. The Court of Appeals transferred the case to the Supreme Court of Georgia.The Supreme Court of Georgia affirmed the conviction. It held that the father was not in custody for Miranda purposes during the initial portion of his police interview, so Miranda warnings were not required until later. Any error in admitting evidence of prior difficulties between the father and the child was deemed harmless, as the evidence was cumulative of other unchallenged testimony. Lastly, the trial court properly exercised its discretion in denying the motion for a new trial, acting as the “thirteenth juror” and citing the applicable legal standards. View "SCOTT v. THE STATE" on Justia Law

In this case, the appellant pled guilty to the malice murder of Willie Jacox following a negotiated plea agreement. The shooting occurred after a dispute between the appellant and Jacox, which stemmed from personal tensions. At the time of the incident, the appellant and his co-defendant, who were dating, arranged to meet Jacox. The appellant, feeling disrespected, ambushed Jacox and fired multiple gunshots, resulting in Jacox’s death. Immediate police investigation led to the arrest of both defendants and the recovery of evidence linking the appellant to the crime, including matching ballistics and a positive gunshot residue test. During his guilty plea hearing, the appellant affirmed he understood his rights, had reviewed the plea form with counsel, and was entering his plea voluntarily.After sentencing, the appellant filed a motion to withdraw his guilty plea in the Superior Court of Houston County, arguing that his plea was not knowing and voluntary and that his counsel was ineffective. At the hearing, plea counsel testified to thorough preparation and review of evidence with the appellant, while the appellant claimed he was misled about the sentence and not adequately informed. The trial court found plea counsel’s testimony more credible, determined the appellant understood his plea and its consequences, and denied the motion, concluding there was no manifest injustice.On appeal, the Supreme Court of Georgia reviewed the denial for abuse of discretion. The Court held that the trial court did not abuse its discretion, finding the appellant’s guilty plea was made knowingly, voluntarily, and intelligently under the totality of circumstances. The Court also held that the appellant failed to establish ineffective assistance of counsel, as the trial court was entitled to credit plea counsel’s testimony over the appellant’s. Accordingly, the judgment denying the motion to withdraw the guilty plea was affirmed. View "MURRAY v. THE STATE" on Justia Law