Justia Georgia Supreme Court Opinion Summaries

In 2011, a jury found Marlina Hamilton guilty of felony murder and other crimes in connection with the shooting death of her ex-husband Christopher Donaldson. In 2015, the trial court granted Hamilton's motion for a new trial on the general and other grounds. At trial, Hamilton argued she shot Donaldson I self-defense and that she suffered from battered-person syndrome. The defense presented an expert witness who testified about battered person syndrome; the State cross-examined the expert but did not present any contrary expert testimony. The State argued that Hamilton had obtained a gun for the purpose of committing an aggravated assault against Donaldson, that she was the initial aggressor in the fatal altercation, and that she did not suffer from battered person syndrome. The jury acquitted Hamilton of malice murder, but found her guilty of the other charges. The trial court then sentenced her to serve life in prison for felony murder and five consecutive years for the firearm charge; the two aggravated assault verdicts merged with the felony murder count. After review, the Supreme Court found that the evidence presented at trial was, when viewed in the light most favorable to the verdicts, legally sufficient to authorize a rational jury to reject Hamilton’s claim of self-defense and find her guilty beyond a reasonable doubt of the crimes for which she was convicted. The State argued that because the evidence was sufficient under the due process standard, the trial court erred in granting a new trial. The Supreme Court held that assertion was incorrect. In this case, the trial court explained that after it carefully reviewed the trial transcript and exhibits and “considered the conflicts in the evidence, the credibility of the witnesses, and the weight of their testimony,” it had concluded that the jury’s guilty verdicts were “decidedly and strongly against the weight of the evidence” and “contrary to the principles of justice and equity.” The court therefore exercised its discretion to grant a new trial. The Supreme Court concluded that the trial court's decision was not an abuse of the trial court’s substantial discretion to act as the “thirteenth juror” in the case. The decision was therefore affirmed and the matter remanded for further proceedings. View "Georgia v. Hamilton" on Justia Law

In 2008, Bernard Robinson was convicted by jury of malice murder, felony murder predicated on aggravated assault, voluntary manslaughter, aggravated assault, and possession of a firearm by a convicted felon. He appealed the malice murder and possession charges, arguing the evidence was insufficient to support the verdict, that he received ineffective assistance of trial counsel, and the trial court erred by not removing a certain juror. Finding no reversible error, the Supreme Court affirmed Robinson's convictions. View "Robinson v. Georgia" on Justia Law

Homer Bryson, in his capacity as commissioner, appealed the grant of habeas relief to Fanoris Jackson. Bryson argued the habeas court erred by finding that Jackson's appellate counsel rendered ineffective assistance by failing to preserve for direct appeal any claim that trial counsel performed deficiently. Finding that the habeas court record did not support the finding that trial counsel provided ineffective assistance, the Supreme Court reversed and remanded. View "Bryson v. Jackson" on Justia Law

Rickey Patterson was convicted on "aggravated assault with an object" when after an argument with his girlfriend's adult son ended with Patterson going to his vehicle, putting it into gear, revving the engine, and rapidly driving directly toward the end of the home, near the son, who became pinned against the side of the home by the vehicle. The son suffered internal injuries. The Georgia Supreme Court granted certiorari to the Court of Appeals to respond to two issues: (1) whether the Appeals Court erred in concluding that the crime of simple assault did not require that the defendant have the specific intent to cause the alleged victim of the assault to suffer injury or the apprehension of injury; and (2) if the Court of Appeals did so err, whether it further erred in concluding that the trial court properly refused to instruct the jury on the crimes of reckless conduct and reckless driving as lesser included offenses of aggravated assault. The Supreme Court concluded the appellate court did not err in its conclusions, and affirmed. View "Patterson v. Georgia" on Justia Law

This was the second appeal stemming from a petition for writ of habeas corpus filed by appellant Michael Lejeune. In that petition, appellant contended that his guilty plea to murder in November 2005 was not knowingly and intelligently entered because “he never was adequately advised of his privilege against self-incrimination.” The habeas court denied relief, finding that appellant was aware of his privilege against compulsory self-incrimination and concluding that appellant’s plea was thus constitutionally valid. In the first appeal, the Georgia Supreme Court concluded that the habeas court’s findings were not supported by the record. The Court also concluded that the trial court had improperly placed the burden of proof on the warden and remanded the case for a new evidentiary hearing with appellant bearing the burden of proof. On remand, the habeas court concluded that appellant was sufficiently aware of his right against self-incrimination and that his plea was thus entered knowingly and voluntarily. The Supreme Court granted appellant’s application for certificate of probable cause to appeal, and now reversed the habeas court’s ruling that appellant’s plea was entered knowingly and voluntarily. View "LeJeune v. McLaughlin" on Justia Law

Ricky Patterson lived in a mobile home with his girlfriend, Wanda Bartley. While her adult son, Nathaniel Silvers, was present, Patterson and Bartley argued, and Bartley and Silvers urged Patterson to leave the home. When Patterson, Bartley, and Silvers were outside the home, Patterson went to his vehicle, put it into gear, revved the engine, and rapidly drove directly toward the end of the home, near Silvers, who became pinned against the side of the home by the vehicle; Silvers suffered internal injuries. The Georgia Supreme Court granted certiorari to the Court of Appeals to answer two questions: (1) whether that the Court of Appeals erred in concluding that the crime of simple assault as set forth in OCGA § 16-5-20 (a) (2) did not require that the defendant have the specific intent to cause the alleged victim of the assault to suffer injury or the apprehension of injury; and (2) if the Court of Appeals did so err, whether it further erred in concluding that the trial court properly refused to instruct the jury on the crimes of reckless conduct and reckless driving as lesser included offenses of aggravated assault. Finding no reversible error, the Supreme Court affirmed. View "Patterson v. Georgia" on Justia Law

In 1991, Anthony Brooks was charged with felony murder and attempted armed robbery. At a plea hearing in January 1992, Brooks, represented by two attorneys, pled guilty to both charges. Brooks was sentenced to life in prison for felony murder and a concurrent probated sentence of ten years for attempted armed robbery. On January 20, 2015, Brooks filed a motion for an out-of-time appeal from his guilty pleas and also moved for an evidentiary hearing thereon. The trial court denied both motions. Brooks appealed the denial of his motions for an out-of-time appeal, and for an evidentiary hearing. Finding no reversible error, the Supreme Court affirmed the denial. View "Brooks v. Georgia" on Justia Law

Appellant Ronald Fisher was found guilty of malice murder and other crimes in connection with the shooting death of Derrick Cullins. At Appellant’s trial, the bulk of the evidence against him (including the only testimony directly identifying him as the shooter) came from David Lewis, who claimed that he was not involved in the crimes even though he admitted that he drove Appellant and the victim to the crime scene, was present during the shooting, and drove Appellant away afterwards. Defense counsel sought to call a witness to impeach Lewis' testimony, but that witness did not show for trial. Defense counsel also agreed to a jury instruction that the testimony of a single witness was generally sufficient to establish a fact without requesting an instruction on an exception that if the witness was an accomplice, his testimony should have been properly corroborated. Fisher appealed when he was ultimately convicted, raising his counsel's allegedly constitutionally ineffective assistance. The Georgia Supreme Court concluded that defense counsel's performance was indeed constitutionally ineffective, and reversed Appellant's convictions. However, because the evidence at trial was legally sufficient to support the guilty verdicts, the State could retry him if it chose. View "Fisher v. Georgia" on Justia Law

In 2012, Thad Ashley was convicted of kidnapping a seven-year-old girl, attempting to kidnap her three-year-old sister, and criminal trespass at the trailer park where his father lived. At trial, the jury heard evidence of these crimes as well as evidence of three earlier incidents at the trailer park’s pool when Ashley had behaved inappropriately towards young children. The trial court admitted the evidence of these other incidents as similar transaction evidence under Georgia’s old Evidence Code, which applied at the time of Ashley’s trial, for the purpose of showing his intent when he engaged in the acts alleged in the indictment and his desires towards young children. Ashley appealed, contending among other things that the trial court abused its discretion when it admitted the similar transaction evidence. In a split decision, the Court of Appeals agreed and reversed Ashley’s convictions on that ground. The Georgia Supreme Court concluded the appellate court erred in its decision, reversed and remanded with direction to consider Ashley's other challenges to his convictions. View "Georgia v. Ashley" on Justia Law

In May 1999, a jury convicted Shaun Metoyer of numerous counts of armed robbery and related offenses, after which he was sentenced to consecutive life sentences. The Court of Appeals affirmed Metoyer’s convictions and sentences. Metoyer subsequently filed a habeas petition in which he argued, among other things, that he received ineffective assistance of appellate counsel. The habeas court agreed with Metoyer and granted his petition; the Warden appealed. Agreeing that Metoyer received ineffective assistance of appellate counsel, the Supreme Court affirmed the habeas court. View "Taylor v. Metoyer" on Justia Law