Justia Georgia Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Georgia Supreme Court granted certiorari in this case to address whether Georgia’s new Juvenile Code required a party to follow the interlocutory appeal procedures laid out in OCGA 5-6-34 (b) when appealing an order concerning the transfer of a case from juvenile to superior court. The Court held that it did not and, in so doing, reversed the decision of the Court of Appeals and remanded the case to be decided on the merits. View "In the Interest of K.S., a child" on Justia Law

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This case was a “John Doe” appeal from the denial of a motion to seal the records of a criminal case pursuant to OCGA 35-3-37 (m). In July 2006, Doe pled guilty to possession of marijuana as a first-time drug offender and was sentenced to five years on probation without entry of a judgment of guilt The Court of Appeals transferred the appeal to the Georgia Supreme Court on the sole basis of the Supreme Court’s exclusive appellate jurisdiction in "all cases in which the constitutionality of a law, ordinance, or constitutional provision has been drawn in question." After review, the Supreme Court concluded this appeal did not invoke its Court’s constitutional-question jurisdiction, and accordingly, returned the case to the Court of Appeals. View "Doe v. Georgia" on Justia Law

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Appellant Anthony Lee Douglas was convicted of malice murder and associated offenses in connection with the shooting deaths of Keith Davis and Charles Avent and the wounding of Sheldon Thomas. On appeal, Appellant contended that the trial court erroneously denied his motion to suppress and improperly admitted other acts evidence under OCGA 24-4-404 (b). Though the Georgia Supreme Court concluded Appellant was erroneously sentenced, the Court otherwise affirmed, and remanded for resentencing. View "Douglas v. Georgia" on Justia Law

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Stephanie Stephens appealed several convictions stemming from the death of her child, Jewell, from cocaine poisoning. Stephens was ultimately sentenced on only one count, felony murder predicated on possession of cocaine with intent to distribute. She argued the evidence was insufficient on that count because the State failed to prove a nexus between the underlying felony and her child’s death. The Georgia Supreme Court rejected that argument, and the same argument in the appeal of her co-defendant, with whom Stephens was tried jointly. Her remaining arguments addressed counts that the trial court merged or effectively vacated, and thus are moot. As such, the Supreme Court affirmed the conviction. View "Stephens v. Georgia" on Justia Law

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Appellant Clifford White was found guilty of murdering his wife, Linda in 2008. She was discovered by appellant’s brother-in-law in a freezer, partially dressed with a bag over her head. The cause of death was listed as blunt force trauma to the head. Appellant appealed his conviction, arguing the evidence was insufficient to sustain his malice murder conviction, and that he received ineffective assistance of trial counsel. Finding no reversible error, the Georgia Supreme Court affirmed. View "White v. Georgia" on Justia Law

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Darrell Hendrix was convicted by jury for felony murder, drug-related and gang-related crimes. On appeal to the Georgia Supreme Court, he contended the evidence was insufficient and that the trial court erred by admitting certain witness testimony pursuant to OCGA 24–8–804 (b) (5). After review of the specific facts of this case, the Georgia Court found the evidence admitted was sufficient to support Hendrix’s convictions, and affirmed. View "Hendrix v. Georgia" on Justia Law

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Damion Clayton was shot and killed in a baseball park in Macon. In March 2014, a grand jury indicted Appellant Jedarrius Meadows, Roland Watson, and Trayvon Starks for malice murder and felony murder; in June, they were reindicted on those two murder charges along with aggravated assault, armed robbery, and two counts of gang activity. Appellant’s trial was severed, and his co-indictees agreed to testify for the State. Appellant challenged the trial court’s denial of his plea in bar based on double jeopardy after the court, sua sponte and over Appellant’s objection, declared a mistrial of his murder trial during jury deliberations. In its order denying the plea, the court said that the deliberations were contentious and that it declared the mistrial “in the interest of juror safety.” Having reviewed the record, the Georgia Supreme Court concluded the trial court declared the mistrial without sufficient factual support and without considering less drastic alternatives to terminating the trial. Because there was no manifest necessity for a mistrial, the Supreme Court reversed the denial of the plea in bar. View "Meadows v. Georgia" on Justia Law

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Armando Soto appealed his convictions for malice murder and other crimes in connection with the 2009 shooting death of Angelica Robledo. Soto argued on appeal to the Georgia Supreme Court that the evidence was insufficient to support his malice murder conviction, the trial court erred in failing to charge on the lesser included offenses of reckless conduct and terroristic threats, and the trial court erred in denying his motions in limine to exclude the victim’s statements about being harassed by a dangerous man and to exclude evidence about his immigration status. The Supreme Court affirmed the convictions, finding the evidence was sufficient to support Soto’s convictions and that the trial court did not err in refusing to charge on the lesser included offenses. Furthermore, the Court concluded any evidence that was admitted as a result of the trial court’s allegedly erroneous denial of Soto’s motions in limine did not affect the outcome of the trial. View "Soto v. Georgia" on Justia Law

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In October 2005, a grand jury indicted Xavier Snelson, Jr. for the July 5, 2005 murder, felony murder and aggravated assault of Natilya Smith. In May 2006, Snelson pled guilty to the counts as alleged in his indictment. He was sentenced to life in prison for malice murder; the remaining counts were either merged into the malice murder or vacated by operation of law. Snelson appealed the denial of his motion for an out-of-time direct appeal. Finding no error, the Georgia Supreme Court affirmed the denial. View "Snelson v. Georgia" on Justia Law

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Jahbari Jones appealed his convictions for malice murder and theft by taking in connection with the shooting death of his cousin, Tradae Jones. Jones argued the evidence was insufficient to sustain his convictions and that the trial court erred in instructing the jury during the separate trial on the issue of Jones’s mental competency, in excluding statements Jones made to police by telephone after the shooting and before his arrest, and in not including the lesser offenses of voluntary manslaughter and involuntary manslaughter on the verdict form. After review, the Georgia Supreme Court disagreed and affirmed the convictions. View "Jones v. Georgia" on Justia Law