Justia Georgia Supreme Court Opinion Summaries

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

Deangelo Deshawn Morgan was convicted in 2023 for the fatal shooting of Sabron Mosby and the aggravated assault of Donoven King. The crimes occurred on October 15, 2018, and Morgan was indicted along with Cleavanta Jerrideau and Glenn Darius Smith. Morgan's trial was severed due to a conflict of interest with his counsel, and Jerrideau and Smith were acquitted in their joint trial. Morgan was later found guilty by a jury and sentenced to life in prison with the possibility of parole for malice murder and an additional twenty years for aggravated assault.Morgan's motion for a new trial was denied by the trial court after an evidentiary hearing. He appealed, arguing that the trial court abused its discretion by excluding evidence that the shooting was drug-related and implicating other potential suspects. He also claimed his trial counsel was ineffective for not properly arguing for the admission of this evidence and advising him not to testify.The Supreme Court of Georgia reviewed the case and found that the trial court did not abuse its discretion in excluding the evidence. The court held that the excluded evidence did not raise a reasonable inference of Morgan's innocence and was speculative. Additionally, the court found that Morgan's trial counsel's performance was not deficient, as the advice given was a strategic decision and not patently unreasonable.The Supreme Court of Georgia affirmed the trial court's decision, upholding Morgan's convictions and sentences. View "MORGAN v. THE STATE" on Justia Law

The appellant, Quillian Donta Nelson, was arrested on June 5, 2020, in connection with the shooting death of Darwin Davis. He filed a pre-indictment demand for a speedy trial on August 7, 2020. However, he was not indicted until August 23, 2021. His original defense attorney filed a motion for a continuance in March 2022, and later, a notice of leave for personal reasons. The defense counsel eventually withdrew, and substitute counsel appeared in February 2023. The new defense attorney also filed several notices of anticipated leaves of absence. Nelson filed a motion for an out-of-time statutory demand for a speedy trial in July 2023, which was denied. He then moved to dismiss his indictment on constitutional speedy-trial grounds in October 2023.The trial court denied Nelson's motion to dismiss the indictment, finding that the length of the delay was presumptively prejudicial but attributing the delay to the COVID-19 pandemic and defense counsel's requested continuances. The court weighed the assertion-of-the-right factor against Nelson, noting his late assertion of the right to a speedy trial, and found no evidence of prejudice to his defense.The Supreme Court of Georgia reviewed the case and found that the trial court made several errors. The trial court failed to properly consider the length-of-the-delay factor, made clearly erroneous findings regarding the reasons for the delay and the assertion of the right, and misapplied the law concerning the prejudice factor. The Supreme Court vacated the trial court's order and remanded the case for further consideration of Nelson's motion to dismiss the indictment on constitutional speedy-trial grounds. View "NELSON v. THE STATE" on Justia Law

Amanda Coleman was convicted of malice murder for the death of two-year-old Brooklyn Aldridge. Brooklyn died on March 6, 2018, and Coleman was indicted in August 2018. At trial in October 2019, Coleman was found guilty of both malice murder and felony murder, but the felony murder count was vacated by operation of law. Coleman was sentenced to life in prison without the possibility of parole. She filed a motion for a new trial, which was denied in July 2024. Coleman then appealed to the Supreme Court of Georgia.The trial court admitted evidence of Coleman’s methamphetamine use, which Coleman argued was inadmissible under OCGA § 24-4-403 and OCGA § 24-4-404 (b). The court ruled that the evidence was intrinsic and satisfied Rule 403’s balancing test. Coleman also challenged the reliability of the urine test showing methamphetamine use, but the court allowed it. Additionally, the court limited the testimony of Coleman’s expert witness regarding alternative causes of Brooklyn’s death, ruling that speculative opinions about pneumonia and DIC were inadmissible.The Supreme Court of Georgia reviewed the case and affirmed the trial court’s decisions. The court held that evidence of Coleman’s methamphetamine use was admissible as intrinsic evidence and that its probative value was not substantially outweighed by any unfair prejudice. The court also found that any error in admitting the urine test results was harmless because it was cumulative of Coleman’s own admissions of drug use. Regarding the expert testimony, the court concluded that excluding speculative opinions did not affect the trial’s outcome, as the jury had already rejected the theory of accidental injury.Finally, the court addressed Coleman’s claim of ineffective assistance of counsel, finding no prejudice from the failure to object to the prosecutor’s characterization of reasonable doubt during closing arguments. The court noted that the trial court properly instructed the jury on the correct standard for reasonable doubt. The Supreme Court of Georgia affirmed Coleman’s conviction and sentence. View "COLEMAN v. THE STATE" on Justia Law

Alfred Jermaine Arnold was convicted of malice murder and other crimes related to the death of Loretta Goolsby, who was beaten to death between April 5 and 6, 2019. Arnold was indicted on multiple counts, including malice murder, felony murder, aggravated assault, arson, and theft by taking. The jury found him guilty on all counts, and he was sentenced to life without parole for malice murder, plus additional concurrent sentences for arson and theft. Arnold's motion for a new trial was denied, leading to his appeal.Arnold argued that the evidence was insufficient to support the verdicts, his discovery rights were violated, his trial counsel was ineffective, and the trial court erred in admitting expert testimony. The Supreme Court of Georgia reviewed the case. The court found that the evidence, including cell phone location data, fingerprint evidence, and Arnold's inconsistent statements, was sufficient to support the convictions. The court also determined that there were no discovery violations, as Arnold had been provided with the expert's reports and was aware of the expert's conclusions.Regarding the ineffective assistance of counsel claim, the court concluded that Arnold's trial counsel's performance was not deficient, as they employed a reasonable strategy in handling the fingerprint evidence and cross-examining the expert. Additionally, Arnold failed to demonstrate that he was prejudiced by his counsel's performance, as he did not provide evidence that he would have accepted a plea offer or that an independent expert would have provided different testimony.The court also upheld the trial court's decision to admit the expert testimony under the Daubert standard and OCGA § 24-7-702 (b), finding that the expert was qualified and her methods were reliable. Consequently, the Supreme Court of Georgia affirmed Arnold's convictions. View "ARNOLD v. THE STATE" on Justia Law