Justia Georgia Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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In this case, the appellant was convicted of malice murder and other crimes related to the shooting death of a 73-year-old man named Jack Hough. On the evening of February 7, 2019, Jack was waiting in his car while his wife went into a pharmacy. Witnesses observed a suspicious man in the parking lot, who was later identified as the appellant. The appellant approached Jack's car, demanded money, and shot Jack when he reached for a gun. Jack later died from his injuries. The appellant was arrested after investigators matched his fingerprints to those found on Jack's car and he made incriminating statements during an interview.The Hall County grand jury indicted the appellant on multiple counts, including malice murder and felony murder. At trial, the jury found him guilty of all counts except robbery and one count of felony murder. The trial court sentenced him to life in prison with the possibility of parole for malice murder, along with additional consecutive sentences for other charges. The appellant filed a motion for a new trial, which was denied by the trial court. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the case and affirmed the lower court's decision. The court held that the evidence was sufficient to support the appellant's conviction for malice murder. The court also found that any error in admitting evidence of the appellant's prior robbery conviction was harmless, given the strong evidence of his intent to commit robbery. Additionally, the court concluded that the trial court did not err in failing to instruct the jury on accident, as the evidence showed the appellant acted with criminal intent. The appellant's convictions and sentences were upheld. View "BENNETT v. THE STATE" on Justia Law

Posted in: Criminal Law
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Stefan Parker was convicted of malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a crime related to the shooting death of Shelbra Lee Stallings. The incident occurred on February 28, 2021, and Parker was indicted in November 2021. A jury found him guilty on all counts in March 2023, and he was sentenced to life in prison plus a consecutive five-year term. Parker filed a motion for a new trial, which was denied in April 2024. He then appealed to the Supreme Court of Georgia.The trial court denied Parker's trial counsel's motion to withdraw, and the court admitted a book found in Parker's possession into evidence. Parker argued that the evidence was insufficient to disprove his self-defense claim, the trial court erred in denying the motion to withdraw, and he received ineffective assistance of counsel. The trial court found that granting the motion to withdraw would have delayed the trial, and the book's admission was deemed harmless given the strong evidence against Parker.The Supreme Court of Georgia reviewed the case and concluded that the evidence was sufficient for the jury to reject Parker's self-defense claim. The court found no reversible error in the trial court's denial of the motion to withdraw or the admission of the book into evidence. Additionally, the court determined that Parker's counsel was not ineffective for stipulating to the authenticity of evidence that was consistent with Parker's self-defense claim. The court affirmed Parker's convictions. View "PARKER v. THE STATE" on Justia Law

Posted in: Criminal Law
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The appellant was convicted by a Gwinnett County jury of felony murder and aggravated assault in connection with the shooting death of his stepfather, Christopher Grier. The incident occurred during an Easter Sunday cookout at the family home, where the appellant, his mother, and his half-sister lived with Grier. The appellant shot Grier twice in the chest after an argument, and Grier was unarmed at the time. The appellant fled to New York, where he later turned himself in, admitting to a transit officer that he had done something "really, really bad."The appellant was indicted for malice murder, felony murder, and aggravated assault. The jury acquitted him of malice murder but found him guilty of felony murder and aggravated assault. The trial court sentenced him to life in prison for felony murder, merging the aggravated assault count. The appellant's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case. The appellant argued that the trial court gave a coercive jury instruction, his defense counsel was ineffective, and the cumulative effect of these errors warranted a new trial. The court found that the trial court's instructions about deliberation time were administrative and not coercive. The court also determined that the defense counsel's performance was not deficient and that any potential errors did not prejudice the appellant's defense. The court concluded that there were no cumulative errors that affected the trial's outcome.The Supreme Court of Georgia affirmed the trial court's order denying the appellant's motion for a new trial. View "EDWARDS-TUGGLE v. THE STATE" on Justia Law

Posted in: Criminal Law
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Leon Lamar Tripp was arrested on May 23, 2017, in connection with the disappearance of Latania Janell Carwell, his stepdaughter. Janell's remains were found on March 8, 2018, leading to Tripp's indictment for murder, kidnapping, and other crimes. Tripp was interviewed multiple times by law enforcement and later sought to suppress these custodial statements. The trial court granted in part and denied in part Tripp's motions to suppress.The trial court ruled that Tripp's statements from May 23, 2017, and June 2, 2017, were admissible, finding they were made voluntarily and after a proper Miranda waiver. However, the court suppressed statements made after June 8, 2017, including those from a June 9, 2017, interview, concluding that Tripp had invoked his right to counsel during this interview. The State appealed the suppression of the June 9 interview, while Tripp cross-appealed the admissibility of the May 23 and June 2 interviews and the partial suppression of the June 9 interview.The Supreme Court of Georgia reviewed the case and affirmed the trial court's decision regarding the admissibility of the May 23 and June 2 interviews, agreeing that Tripp had voluntarily waived his Miranda rights. However, the court reversed the suppression of the entire June 9 interview, determining that Tripp's statements before 3:37 p.m. were spontaneous and not elicited by interrogation, and thus should not have been suppressed. The court held that only the statements made after 3:37 p.m., when Tripp's attorney advised him to remain silent, were inadmissible. View "THE STATE v. TRIPP" on Justia Law

Posted in: Criminal Law
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Jasmine Williams was found guilty of malice murder in connection with the shooting death of Gregory Swinson. The incident occurred on or about September 16, 2017, and Swinson succumbed to his injuries a few days later. Williams and Swinson had a tumultuous relationship, and on the night of the incident, they had been drinking and arguing. Swinson had visible injuries, and after a confrontation at Williams's house, she shot him. Williams claimed the shooting was accidental.The Coffee County grand jury indicted Williams for felony murder and malice murder. In October 2018, a jury found her guilty on both counts, and the trial court sentenced her to life in prison without the possibility of parole for malice murder, with the felony murder count vacated by operation of law. Williams filed a motion for a new trial, which was denied by the trial court. She then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the case and addressed several arguments raised by Williams. First, the court found no abuse of discretion in the trial judge's decision not to recuse himself, as the conversation in question did not involve the pending trial and did not create an appearance of impropriety. Second, the court held that the trial court did not err in refusing to charge the jury on self-defense, accident, and voluntary manslaughter, as the evidence did not support these defenses. Finally, the court concluded that Williams's trial counsel was not constitutionally ineffective for withdrawing the request to charge on defense of habitation, as Williams failed to show that the outcome of the trial would have been different had the charge been given.The Supreme Court of Georgia affirmed the trial court's judgment, upholding Williams's conviction and sentence. View "THE STATE v. LEVERETTE" on Justia Law

Posted in: Criminal Law
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Ammon Sumrall was convicted in October 1992 by a DeKalb County jury of felony murder, armed robbery, and other crimes related to the shooting death of Wade Barrett, Jr. on April 7, 1991. He was sentenced to two consecutive life sentences plus five additional years. Over 30 years later, Sumrall filed a pro se petition in the Superior Court of DeKalb County seeking retroactive first-offender treatment based on an amendment to OCGA § 42-8-66. He also filed a motion to declare the statute unconstitutional.The trial court initially dismissed Sumrall’s petition and motion, but later vacated this order and issued an amended order. The amended order dismissed the petition for failing to obtain the necessary consent from the prosecuting attorney and denied the motion to declare the statute unconstitutional, citing a lack of standing and insufficient supporting arguments.The Supreme Court of Georgia reviewed the case and affirmed the trial court’s decisions. The court held that Sumrall failed to meet the statutory requirement of obtaining the prosecuting attorney’s consent before filing his petition for retroactive first-offender treatment. The court also found no merit in Sumrall’s argument that the prosecuting attorney’s inaction constituted implied consent. Additionally, the court upheld the trial court’s denial of Sumrall’s motion to declare OCGA § 42-8-66 (a) (1) unconstitutional, concluding that Sumrall did not demonstrate a clear and palpable conflict with the Georgia or United States Constitutions. The court emphasized that the statute did not deprive Sumrall of his right to access the courts or to be heard. View "Sumrall v. State" on Justia Law

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Jarrod James Hayes was convicted of malice murder and other crimes related to the shooting death of Zedekiah Jones. Hayes argued that the trial court erred in denying his motion to suppress three firearms found at his home, which he disclosed without receiving Miranda warnings. He also claimed ineffective assistance of counsel, improper admission of a witness's video statement, refusal to bifurcate charges, and failure to instruct the jury on voluntary manslaughter and mutual combat.A Douglas County grand jury indicted Hayes on multiple charges, including malice murder and possession of a firearm by a convicted felon. The marijuana possession charge was dropped, and Hayes was found guilty on all remaining charges. He was sentenced to life in prison without parole for malice murder and additional concurrent terms for the weapons charges. Hayes's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case and held that the firearms were admissible because Hayes's statement about their location was voluntary, despite the lack of Miranda warnings. The court also found no merit in Hayes's other claims. The court concluded that the trial court did not abuse its discretion in admitting the witness's prior inconsistent statement, denying the motion to bifurcate charges, or refusing to give jury instructions on voluntary manslaughter and mutual combat. The court also determined that any errors by trial counsel did not result in prejudice sufficient to undermine confidence in the trial's outcome. Consequently, the Supreme Court of Georgia affirmed Hayes's convictions and sentences. View "Hayes v. State" on Justia Law

Posted in: Criminal Law
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Lewarner Jaron Scott was convicted of murder and other crimes related to the shooting death of Kevin Compton. The incident occurred on July 12, 2014, at a nightclub in Kennesaw, Georgia. A bottle was thrown, injuring Scott’s friend, Jawaree Hill, which led to an altercation. Compton, along with his friends Brandon McMurtry and McKinley Bain, decided to leave the club. As they were driving out of the parking lot, gunshots were fired, and Compton was fatally shot in the head. Witnesses identified a man with dreadlocks and a blue shirt carrying a gun before and after the shooting. Scott was later identified as the man seen with the gun and driving a gray Dodge Neon.A Cobb County grand jury indicted Scott on multiple charges, including malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. In August 2015, a jury found Scott guilty on all counts. The trial court sentenced him to life in prison plus additional consecutive sentences for other charges. Scott’s trial counsel filed a motion for a new trial, which was later amended by his post-conviction counsel. The trial court denied the motion for a new trial in August 2023, and Scott’s counsel filed a timely notice of appeal.The Supreme Court of Georgia reviewed the case and concluded that the evidence was sufficient to support Scott’s convictions beyond a reasonable doubt. The court noted that the jury was authorized to reject alternative hypotheses presented by Scott and found that the circumstantial evidence, including witness testimonies and forensic evidence linking the spent casings to Scott’s gun, supported the verdict. The court affirmed the judgment, upholding Scott’s convictions and sentences. View "Scott v. State" on Justia Law

Posted in: Criminal Law
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Andrew Troutman was convicted of malice murder for the stabbing death of Earl Clemons. The incident occurred in January 2014, and Troutman was indicted on charges of malice murder, felony murder, and aggravated assault. The case involved a pre-trial appeal where the trial court's decision to suppress a statement made by Troutman to the police was partially affirmed and partially reversed by the Supreme Court of Georgia. At trial in August 2019, the jury found Troutman guilty on all counts, and he was sentenced to life with the possibility of parole. Troutman filed a motion for a new trial, which was denied, leading to this appeal.The trial court's decision was based on evidence including threats made by Troutman against Clemons, Troutman's presence at the crime scene, and his confessions to his uncle and former girlfriend. The jury also heard about a fake DeVry student ID found in Troutman's room and his inconsistent statements to the police. The trial court's suppression of part of Troutman's confession did not affect the sufficiency of the evidence.The Supreme Court of Georgia reviewed the case and found the evidence constitutionally sufficient to support the conviction. The court held that OCGA § 24-14-6, which pertains to circumstantial evidence, did not apply because there was direct evidence of Troutman's guilt. Claims of prosecutorial misconduct were either not preserved for review or resolved in Troutman's favor. The court also found that Troutman did not prove prejudice from his claims of ineffective assistance of counsel, including the decision to present an alibi defense and the failure to object to certain prosecutorial comments during closing arguments.The Supreme Court of Georgia affirmed the trial court's judgment, concluding that the evidence was sufficient to support the conviction and that Troutman did not demonstrate that any alleged errors by his trial counsel affected the outcome of the trial. View "Troutman v. State" on Justia Law

Posted in: Criminal Law
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Kaylon Janard Jiles was found guilty of felony murder and other crimes related to the shooting death of Eris Fisher. Fisher and his associate, Laura Griffin, had been buying and selling cocaine together. Fisher contacted Jiles to purchase cocaine, but after receiving it, Fisher complained that the weight was off. Jiles agreed to deliver more cocaine to Fisher. When Fisher arrived at the motel parking lot to meet Jiles, Jiles and two other men approached and shot Fisher. Fisher's wife, Maryanne Crawford, and Griffin witnessed the shooting. Crawford initially lied to officers about the motive for the shooting, and Griffin disposed of a gun found near Fisher's body.The DeKalb County grand jury indicted Jiles and Traquan McLeod for multiple charges, including malice murder and felony murder. McLeod pleaded guilty to reduced charges, while Jiles went to trial. The jury acquitted Jiles of malice murder and gang activity but found him guilty of felony murder and other charges. The trial court sentenced Jiles to life in prison without parole. Jiles filed a motion for a new trial, which was denied, leading to this appeal.The Supreme Court of Georgia reviewed the case. Jiles argued that the trial court erred by not instructing the jury on accomplice corroboration and that his trial counsel was ineffective. The court found no plain error in the jury instructions and determined that Jiles's counsel's performance was not deficient. The court also found that any presumed errors did not likely affect the trial's outcome. The Supreme Court of Georgia affirmed Jiles's convictions, concluding that the cumulative prejudice from the alleged errors did not warrant a new trial. View "Jiles v. State" on Justia Law

Posted in: Criminal Law