Justia Georgia Supreme Court Opinion Summaries

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

Appellant Johnny Rammage was convicted of malice murder and a firearm offense in connection with the shooting death of Chris Johnson. On appeal, he argued the trial court erred: (1) by not allowing him to introduce evidence of Johnson’s prior acts of violence; (2) by declining to give jury instructions on justification and accident; and (3) by admitting evidence of his prior conviction. Appellant also contended his trial counsel provided ineffective assistance by not objecting to the court’s failure to give the jury instructions. After review of the record and the briefs, the Georgia Supreme Court found no reversible error and affirmed. View "Rammage v. Georgia" on Justia Law

In 2016, Deonta Rich was convicted of murdering Sylvester Downs and kidnapping Taquoya Rogers. Rich: (1) challenged the sufficiency of the evidence to support his convictions; (2) argued the trial court erred by denying his motion for new trial while sitting as the thirteenth juror; and (3) contended his trial counsel was ineffective for failing to object after the State, during its closing argument, inappropriately commented on his prior juvenile adjudication. Finding no reversible error, the Georgia Supreme Court affirmed. View "Rich v. Georgia" on Justia Law

Sylvester Taylor was convicted by jury for malice murder and criminal attempt to commit rape, amongst other crimes, stemming from the beating death of Linda Madison. This appeal stemmed from an exchange between Taylor and the judge presiding over his pre-trial proceedings, specifically, at a 2014 preliminary hearing, wherein Taylor proclaimed “I ain’t killed that b*tch; that b*tch killed herself.” The trial court then cautioned, “Wait a minute.” Taylor, however, immediately launched into an uninterrupted (albeit brief), profanity-laced tirade in which he denied killing Madison. The tirade culminated in him saying, “Y’all can kiss my black a**.” The trial court found Taylor guilty of 13 instances of criminal contempt, one for each of the obscene words that he used during the outburst, and sentenced him to a total of 230 days in jail, not to be served until Taylor became eligible for release pursuant to bond or “by final disposition of the charges upon which [Taylor] is currently being held.” Taylor appealed, contending (among other things) that the trial court erred by finding him guilty of multiple instances of contempt. The State agreed with Taylor, and so did the Georgia Supreme Court. Judgment was vacated and the matter remanded for further proceedings. View "Taylor v. Georgia" on Justia Law