Justia Georgia Supreme Court Opinion Summaries

Michelle Wierson was charged with vehicular homicide after allegedly causing a fatal car accident while speeding. Two psychiatrists concluded that Wierson lacked the mental capacity to distinguish right from wrong and suffered from a delusional compulsion at the time of the accident. Wierson filed a notice of intent to plead not guilty by reason of insanity. The State moved to introduce evidence that Wierson had stopped taking some of her psychiatric medications before the accident. The trial court granted the State's motion.The Court of Appeals reversed the trial court's decision, holding that evidence of medication non-compliance was not relevant to the statutory defenses of insanity. The court explained that the insanity-defense statutes do not mention how or why a defendant may have come to her mental state, only that she is not guilty if she has that mental state at the time of the offense. The court also held that evidence of medication non-compliance was not relevant to show Wierson’s intent to commit vehicular homicide and reckless driving.The Supreme Court of Georgia reviewed the case to determine whether evidence that a defendant voluntarily contributed to her mental state is relevant to the statutory insanity defenses and whether the precedent set in Bailey v. State should be reconsidered. The court concluded that the plain language of the insanity-defense statutes does not provide any exception for voluntary inducement of the mental state. The court overruled Bailey, which had held that the insanity defenses are not available to a defendant who voluntarily induced the relevant mental state. The Supreme Court of Georgia affirmed the Court of Appeals' judgment, holding that evidence of Wierson’s medication non-compliance was not admissible to show that she voluntarily induced her lack of mental capacity or delusional compulsion. View "THE STATE v. WIERSON" on Justia Law

Angelo Short was convicted of malice murder and related crimes, including burglary, theft, robbery, and obstruction of an officer, following the stabbing death of Peggy Gamble in November 2016. Short was sentenced to life in prison without parole plus 40 years. He appealed, challenging the trial court's admission of his incriminating statements made during custodial interviews with Columbus Police Department officers, arguing that his confession was induced by promises of benefit and threats of harm.The Muscogee County grand jury indicted Short on multiple charges, and he was tried and found guilty on all counts by a jury in November 2019. Short filed a motion for a new trial, which was denied by the trial court after an evidentiary hearing. He then filed a timely notice of appeal.The Supreme Court of Georgia reviewed the case and affirmed the trial court's decision. The court held that Short's confession was admissible, as it was not induced by the slightest hope of benefit or remotest fear of injury, as required by OCGA § 24-8-824. The court found that the officers' statements during the interviews did not amount to promises of reduced punishment or threats that would render the confession involuntary. The court also noted that any statements made by the officers about potential plea deals or sentencing were noncommittal and did not constitute improper inducements. Additionally, the court found no evidence that Short's fear of harm from other inmates was used by the officers to coerce his confession. Consequently, the court affirmed the trial court's judgment and the admissibility of Short's confession and the physical evidence obtained as a result. View "SHORT v. THE STATE" on Justia Law

Robert Kyle Dougherty was convicted of felony murder and other crimes related to the shooting death of Trevorius Thomas. Dougherty and his co-indictee, Stephen Lober, planned to rob Thomas by luring him to an abandoned house under the pretense of a drug deal. During the encounter, Thomas was shot and killed. Dougherty and Lober then attempted to cover up the crime. Dougherty was found guilty of all charges except malice murder, and the trial court sentenced him to life in prison with the possibility of parole, along with additional consecutive and concurrent prison terms for other charges.Dougherty's first appeal was dismissed because his pro se motion for a new trial was a legal nullity, and his appellate counsel's motion was untimely. His subsequent appeals were also dismissed due to unresolved issues with Count 4 and procedural errors. After the trial court entered an order of nolle prosequi for Count 4, Dougherty's third appeal was dismissed based on the law of the case doctrine. On remand, Dougherty filed a motion to correct an illegal sentence, which was granted, and he was resentenced to the same total time. His motion for a new trial was denied, leading to the current appeal.The Supreme Court of Georgia reviewed the case and affirmed the trial court's decisions. The court held that the evidence was sufficient to support Dougherty's convictions for felony murder and conspiracy to commit armed robbery. The court also found that the trial court did not abuse its discretion in admitting certain text messages and in imposing Dougherty's sentence. The court rejected Dougherty's arguments regarding sentencing disparity and improper considerations during sentencing, concluding that the trial court's comments were reasonable inferences based on the evidence presented at trial. View "DOUGHERTY v. THE STATE" on Justia Law

Benjamin Clarence McIver was convicted of malice murder and other crimes related to the shooting death of Brandon Smith. The crimes occurred on April 16, 2020. McIver, along with Antavius Wilcox and James Parker, was reindicted on March 25, 2021. McIver and Wilcox faced multiple charges, including malice murder and armed robbery. McIver was tried separately and found guilty on all counts on June 30, 2022. He was sentenced to three consecutive life terms without parole for malice murder, armed robbery, and kidnapping, plus a consecutive five-year term for possession of a firearm during the commission of a felony.McIver filed a motion for a new trial, which was denied by the trial court on August 12, 2024. He then appealed to the Supreme Court of Georgia. McIver argued that his trial counsel was ineffective, the trial court erred in not suppressing part of his custodial statement, and the evidence was insufficient to support his armed robbery conviction.The Supreme Court of Georgia reviewed the case and found that McIver's trial counsel was not ineffective. The court determined that counsel's strategic decisions, including not presenting expert testimony on DNA evidence and not filing a pre-trial motion challenging the DNA testing, were reasonable. The court also found no plain error in the trial court's handling of McIver's custodial statement.However, the court agreed with McIver that the evidence was insufficient to support his armed robbery conviction. The court reversed the armed robbery conviction and remanded the case for resentencing, as the reversal affected the merger of the aggravated assault count and the consecutive nature of the kidnapping and firearm possession sentences. The court affirmed McIver's remaining convictions. View "MCIVER v. THE STATE" on Justia Law

Jaquan Dontae Weston was convicted of malice murder and other crimes related to the shooting death of his father, Leroy Weston. The crimes occurred between March 5-6, 2018. A Terrell County grand jury indicted Weston in June 2018, and he was found guilty on all counts in an October 2019 jury trial. Weston was sentenced to life in prison without parole for malice murder, five years consecutive for possession of a firearm during the commission of a felony, and twelve months concurrent for cruelty to children in the third degree. Weston filed a motion for a new trial, which was denied. His appeal was initially stricken due to his appellate counsel's failure to file a brief, but it was later re-docketed after new counsel was appointed.The Supreme Court of Georgia reviewed the case. Weston argued that the evidence was insufficient to support his malice murder conviction and claimed ineffective assistance of trial counsel. The court found that the evidence, viewed in the light most favorable to the verdict, showed that Weston formed the intent and malice necessary for a malice murder conviction. The jury was entitled to find Weston guilty beyond a reasonable doubt based on his actions and statements following his daughter's outcry about her grandfather.Weston also argued that his trial counsel was ineffective for failing to investigate his competency to stand trial, request a competency hearing, and object to certain evidence. However, these claims were not preserved for appellate review as they were not raised in his motion for a new trial. The court also found that Weston failed to show that his trial counsel was ineffective for not obtaining an expert evaluation of his sanity at the time of the crimes, as there was no evidence presented to support this claim.The Supreme Court of Georgia affirmed the trial court's judgment, finding no merit in Weston's arguments. View "WESTON v. THE STATE" on Justia Law

Antonio Ingram pleaded guilty to five felony counts, including armed robbery, aggravated assault, and aggravated battery, on September 30, 2016. The court found his plea was freely and voluntarily entered and entered a judgment of conviction on March 3, 2017, nunc pro tunc to September 30, 2016. Ingram was sentenced to concurrent 20-year prison terms, with 15 years to serve for each conviction. Ingram retained attorney David Jones to file a motion to withdraw his guilty plea, which was timely filed on October 27, 2016. However, there is no evidence that the trial court ruled on the motion, and Jones testified that the motion was dismissed without a hearing on March 3, 2017.The Superior Court of Richmond County granted in part Ingram’s petition for a writ of habeas corpus, allowing him to pursue an out-of-time direct appeal. The court found that Jones rendered ineffective assistance of counsel by failing to inform Ingram of his right to appeal the denial of his motion to withdraw his guilty plea. Ingram cross-appealed, arguing that the habeas court erred in denying him the remedy of setting aside his guilty plea and judgment of conviction.The Supreme Court of Georgia reviewed the case and found that the habeas court erred in treating the March 3 "Order to Enter Sentence" as an order denying Ingram’s motion to withdraw his guilty plea. The record did not demonstrate that Ingram’s judgment of conviction was final for purposes of habeas review. The court vacated the habeas court’s order and remanded the case with directions to allow the parties to supplement the record and demonstrate whether Ingram’s judgment of conviction is final. If the motion to withdraw the guilty plea remains pending, the habeas petition should be dismissed as premature. If the judgment is final, the habeas court may reenter its previous order with that determination. The cross-appeal claims were deemed moot. View "JOSEPH v. INGRAM" on Justia Law

Antonio Wallace, convicted of felony murder in 2011, sought original autopsy photographs for his pending habeas case. He requested these photographs under the Open Records Act, but the District Attorney refused. Wallace then filed a motion in the superior court where he was convicted, arguing that his request fit within exceptions for "medical purposes" or "public interest" under OCGA § 45-16-27 (d).The trial court found Wallace's arguments unconvincing and denied his motion. Wallace was convicted in Ware County, and his conviction was affirmed by the Supreme Court of Georgia in 2020. In 2021, he filed a habeas corpus petition in Wheeler County. In 2024, he filed a motion for limited disclosure of original trial exhibits, specifically the autopsy photographs, to Dr. Jan Gorniak, citing the poor quality of the copies he had.The trial court held a hearing where Wallace's counsel argued that the photographs were necessary to establish ineffective assistance of counsel. The victim's sister opposed the disclosure. The trial court denied the motion, and Wallace appealed, raising the same arguments.The Supreme Court of Georgia reviewed the case and affirmed the trial court's decision. The court held that the disclosure of autopsy photographs was not for "medical purposes" as Wallace's intent was legal, not medical. Additionally, the court found that the disclosure was not "in the public interest" as the victim's family opposed it, and Wallace's arguments did not outweigh their privacy concerns. Thus, the District Attorney was not required to disclose the photographs. View "WALLACE v. THE STATE" on Justia Law

Tanaiveon Johnson was convicted of felony murder and other offenses related to a gang-related shootout in which his friend, Arraffi Williams, was killed. The incident occurred on September 13, 2017, and Johnson was indicted along with five others on September 19, 2018. Johnson faced multiple charges, including felony murder, aggravated assault, and firearm possession. During his trial in October 2021, Johnson was found guilty on all counts, and he was sentenced to life in prison plus a five-year probated sentence for one firearm count. Johnson's motion for a new trial was denied, leading to this appeal.The trial court allowed the State to reopen evidence during jury deliberations to introduce a jail call recording in which Johnson admitted to shooting back to protect the car during the incident. Johnson argued that this was an abuse of discretion, but the Supreme Court of Georgia found no abuse, noting that the State had discovered the call relatively quickly and that Johnson had taken steps to conceal it. The court also gave the defense time to prepare and present additional arguments.Johnson also claimed ineffective assistance of counsel, arguing that his trial counsel pressured him not to testify. The court found that counsel's advice was reasonable given Johnson's communication difficulties and that Johnson had not shown prejudice from not testifying. Johnson's proffered testimony was inconsistent and would not have likely changed the trial's outcome.Finally, Johnson argued that the trial court erred in its jury instructions regarding proximate cause. The Supreme Court of Georgia reviewed this claim for plain error and found that Johnson had not shown that the omission of a specific proximate cause instruction probably affected the trial's outcome. The court affirmed Johnson's convictions. View "JOHNSON v. THE STATE" on Justia Law

Kiwani Khalif Patterson was convicted of malice murder and other crimes related to the shooting death of Tarik Bentley. The crimes occurred on April 24, 2016, and Patterson was indicted on August 17, 2016. A jury found him guilty on all counts during a trial held from February 24 to 26, 2020. On March 5, 2020, the trial court sentenced Patterson to life in prison without the possibility of parole for malice murder and an additional 15-year sentence for possession of a firearm by a convicted felon. Patterson filed a timely motion for a new trial, which was denied on June 10, 2024.Patterson did not timely appeal the denial of his motion for a new trial. Instead, on August 27, 2024, he filed a notice of appeal and a motion for reconsideration and extension of time to file a notice of appeal. On August 29, 2024, the trial court set aside its previous order denying the motion for a new trial and re-entered the order. Patterson then filed a new notice of appeal on September 10, 2024.The Supreme Court of Georgia reviewed whether it had jurisdiction over the appeal, given the untimely notice of appeal. The court concluded that the trial court was divested of jurisdiction once the untimely notice of appeal was filed, rendering the trial court's subsequent orders void. Consequently, the Supreme Court of Georgia vacated the judgment, dismissed the appeal, and remanded the case for further proceedings without addressing the merits of Patterson's contentions. View "PATTERSON v. THE STATE" on Justia Law

Jousha O’Shea Routh was convicted of felony murder and other crimes related to the shooting deaths of Saiful Bhuyia and Rizanul Islam. The incident occurred on September 10, 2017, when Bhuyia, Islam, and two other workers were closing a convenience store. Two men from a white car demanded money, chased Bhuyia and Islam, and shot them. Bhuyia died at the scene, and Islam died days later. Routh was identified through fingerprints on Bhuyia’s car and cell phone records. His girlfriend, Shea Paul, identified him as the shooter based on surveillance footage.A Fulton County grand jury indicted Routh on multiple counts, including malice murder and felony murder. The jury found him not guilty of malice murder of Islam, did not reach a verdict on the malice murder of Bhuyia, and found him guilty on other counts. The trial court sentenced Routh to two consecutive life sentences plus 35 years. Routh filed a motion for a new trial, which was denied by the trial court. He then filed a timely notice of appeal.The Supreme Court of Georgia reviewed the case. Routh argued that the trial court abused its discretion by limiting his cross-examination of the lead detective. The court found that the trial court had discretion to limit cross-examination to prevent unfair advantage and to conclude that questions about the age of fingerprints were outside the scope of the detective’s lay testimony. The court held that the trial court did not abuse its discretion in these rulings and affirmed Routh’s convictions. View "ROUTH v. THE STATE" on Justia Law