Justia Georgia Supreme Court Opinion Summaries

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

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

A grand jury indicted Archie Bryant and Jose Carrillo in connection with the 2017 shooting death of Shawn Rhinehart. The indictment charged Bryant with malice murder, two counts of felony murder, two counts of aggravated assault, and possession of a firearm by a convicted felon. Bryant elected to proceed under reciprocal discovery. The State brought an interlocutory appeal of the trial court’s order to exclude certain evidence on the basis that the evidence was not produced until just over a month before trial, or had not been produced at all, in violation of the trial court’s pre-trial scheduling order. The trial court’s order could stand only if it properly found the State acted with bad faith and that defendant was prejudiced as a result. The Georgia Supreme Court determined the trial court’s order was ambiguous both as to whether the court actually found bad faith on the part of the State at all and as to the basis for the trial court’s finding of prejudice to the defendant. Accordingly, the Supreme Court vacated the trial court’s ruling and remanded for the trial court to clarify its ruling on the defendant’s motion to exclude the evidence. View "Georgia v. Bryant" on Justia Law

Joseph Gittens was convicted by jury of malice murder in connection with the death of fellow inmate Johnny Johnson. Gittens argued on appeal that the evidence was insufficient to sustain his conviction, that trial counsel was constitutionally ineffective, that he was denied the right to communicate freely with counsel, and that newly discovered evidence entitles him to a new trial. Finding no merit to these claims, the Georgia Supreme Court concluded that each claim was without merit and affirmed. View "Gittens v. Georgia" on Justia Law

The Court of Appeals reversed Kenneth Williams’ conviction for aggravated sexual battery based on its conclusion that the trial court gave an erroneous charge to the jury concerning an underage victim’s capacity to consent. The State appealed, arguing the jury instruction did not constitute plain error to warrant reversal of the conviction. The Georgia Supreme Court concurred: the victim was young, the conduct was clearly sexual in nature, the adult was an authority figure in the child’s life, and the evidence was strong. The Court surmised it was unlikely that the trial court’s instruction affected the jury’s decision to return a verdict of guilty for the charge of aggravated sexual battery. “In other words, the jury instruction error did not constitute plain error here given the circumstances.” Accordingly, judgment of the Court of Appeals was reversed as it pertained to Williams’ conviction for aggravated sexual battery. View "Georgia v. Williams" on Justia Law

Tyrecquiss Wells appealed his convictions for felony murder and other crimes in connection with the shooting death of David Scott. Wells argued: (1) the trial court erred in denying his motion to suppress his custodial statements on the ground that he did not knowingly waive his rights; (2) his confrontation right was violated when the trial court admitted an accomplice’s inculpatory statements; and (3) trial counsel was ineffective for failing to file a motion to sever his trial from those of his co-defendants. The Georgia Supreme Court affirmed because: (1) the record showed that Wells knowingly waived his rights when he voluntarily agreed to speak with the police; (2) there was no confrontation violation because the accomplice testified at trial and Wells was able to cross-examine him; and (3) trial counsel’s reason for not filing a motion to sever was not objectively unreasonable. View "Wells v. Georgia" on Justia Law

Jonathan Jackson was convicted of malice murder and possession of a firearm during the commission of a felony in connection with the shooting death of DeAngelo Head. On appeal, Jackson argued only that the evidence was insufficient to sustain his convictions. Finding the evidence to support his conviction, the Georgia Supreme Court affirmed Jackson’s convictions. View "Jackson v. Georgia" on Justia Law