Justia Georgia Supreme Court Opinion Summaries

Roden Meadows appealed his convictions for murder, aggravated assault, and possession of a firearm during the commission of a felony arising from the 2018 fatal shooting of Jason Williams. On appeal, Meadows contended the evidence constitutionally insufficient and that the Georgia Supreme Court should exercise its authority under OCGA §§ 5-5-20 and 5-5-21 as the “thirteenth juror” and grant him a new trial. He also argued the trial court erred in three instances by failing to rebuke the prosecutor for making improper and prejudicial statements during closing arguments. The Supreme Court concluded the evidence was sufficient to sustain Meadows’s convictions, and that it did not have authority under the cited statutory law to sit as the “thirteenth juror.” The Court also concluded Meadows failed to preserve his challenges to two of the prosecutor’s statements during closing arguments, and with respect to the third instance, even if the trial court erred by failing to rebuke the prosecutor, any error was harmless. Although not raised by Meadows on appeal, the Court identified in the record a merger error related to the sentence the trial court entered on Count 3 of the indictment. Because the Supreme Court could not resolve this sentencing issue based on the record, it vacated the merger of and sentence on Count 3 and remanded to the trial court for further proceedings. View "Meadows v. Georgia" on Justia Law

Thaddas Nundra was convicted of murder and many other serious charges related to the 2017 shooting death of Herbert Moore. On appeal, he argued the trial court made four key errors, and the cumulative effect of those errors required reversal. Assuming the trial court made at least two errors as alleged, the Georgia Supreme Court concluded these errors were harmless, both individually and cumulatively. With regard to the remaining errors, the Court determined Nundra did not show it was plain error to allow the State to introduce “TrueAllele” DNA evidence without a baseline of how likely a sample was to match a random person. And certain arguments made by the prosecution "were certainly inflammatory," but based on permissible inferences from evidence in the record. The Court therefore affirmed Nundra's convictions. View "Nundra v. Georgia" on Justia Law

Garry Johnson was convicted of malice murder and robbery in connection with the 1997 killing of Irene Shields. Johnson was sentenced to life in prison without the possibility of parole plus a consecutive 20-year term. For years, the Georgia Supreme Court has applied an absolute rule that anything filed by a criminal defendant on his or her own while still represented by counsel was a “legal nullity.” In this case, the Georgia Court asked the parties and amici whether that rule was correct: is a pro se filing made by a defendant who is actually or presumptively represented by counsel always a nullity? The Court now answers that question in the negative: although a defendant does not have a constitutional or statutory right to represent himself while he is also represented by counsel, nothing in the State Constitution or Code prohibited such “hybrid representation. ...Stare decisis does not require us to perpetuate a legal rule that is so obviously and harmfully wrong, and so we overrule our past decisions to the extent they held that a pro se filing by a counseled defendant is always a legal nullity.” View "Johnson v. Georgia" on Justia Law

Appellant Larry Hood challenged a superior court’s order denying his motion to withdraw his guilty plea to malice murder and other crimes in connection with the death of Angela Ritter Davis. Hood claimed his plea was not knowing, intelligent, and voluntary because his plea counsel made an affirmative misrepresentation about the collateral consequences of his plea (i.e., his parole eligibility). After review of the superior court’s record, the Georgia Supreme Court affirmed the denial of Hood’s motion. However, because the superior court committed sentencing errors, the Supreme Court vacated two of Hood’s convictions and remanded for resentencing. View "Hood v. Georgia" on Justia Law

Edward Behl was convicted by jury for felony murder and a weapons charge stemming from the 2017 death of Joseph Billings, a fellow resident of a homeless encampment. Behl argued for a new trial on the grounds that: (1) the trial court plainly erred in not charging the jury on voluntary manslaughter; and (2) Behl was unable to view digital discovery while incarcerated and while exercising the right to self-representation. After review, the Georgia Supreme Court concluded the trial court did not plainly err in failing to charge the jury on voluntary manslaughter, and that Behl did not preserve the issue of access to discovery. Accordingly, judgment and conviction were affirmed. View "Behl v. Georgia" on Justia Law

Twice previously, Dennis Allaben appealed his conviction for malice murder arising from the strangulation death of his wife, Maureen. On each appeal, the Georgia Supreme Court reversed the conviction and remanded the case, and the case was retried. After Allaben’s third trial was held in December 2016, a jury found him guilty of malice murder, and he again appealed, arguing that the evidence was insufficient to support his conviction for murder and that the State failed to prove venue as required by OCGA § 17-2-2. Finding no reversible error, the Supreme Court affirmed the conviction. View "Allen v. Georgia" on Justia Law

Israel Timothy Williams was convicted by jury of malice murder and possession of a firearm during the commission of a felony in connection with the shooting death of Brandon Colson. Williams challenged the sufficiency of the evidence, contended his trial counsel was ineffective, and argued that the trial court erred in denying his request for a jury instruction on coercion. Because the Georgia Supreme Court found Williams failed to carry his burden of showing reversible error, it affirmed his convictions as well as the trial court’s order denying his motion for a new trial. View "Williams v. Georgia" on Justia Law

Steven Monroe appealed his convictions for malice murder and related offenses arising out of the 2014 shooting death of Clayton Cross and aggravated assaults of Kenneth Minson, Darius Minson, Willie Calhoun, Muhammad Clark, Dominique Ellis, and Craig Harris. Monroe claimed on appeal the evidence was insufficient to support his convictions for violating Georgia’s Gang Act and his convictions on all counts related to Clark. Monroe further alleged the trial court abused its discretion by denying his motion for mistrial based upon alleged juror misconduct, erred by failing to charge the jury on self-defense, improperly admitted opinion evidence at trial, and erred during sentencing. Monroe also alleged he received ineffective assistance of counsel. The Georgia Supreme Court determined the trial court erred in calculating Monroe's sentence, but affirmed the convictions in all other respects. The case was remanded for correction of Monroe's sentence. View "Monroe v. Georgia" on Justia Law

Chad Haufler was convicted by jury in 2021 of malice murder and other crimes in connection with the shooting death of Marc Dimos. On appeal, Haufler argued the trial court erred in failing to instruct the jury on involuntary manslaughter and in denying his pretrial motion to suppress certain statements he made in the presence of law enforcement officers. Finding no reversible error, the Georgia Supreme Court affirmed. View "Haufler v. Georgia" on Justia Law

After Marina Middlebrooks pleaded not guilty by reason of insanity to charges arising from the stabbing death of her daughter, Sky Allen, a jury found Middlebrooks guilty of murder and cruelty to children in the first degree. On appeal, Middlebrooks contended that the trial court erred in allowing the State’s expert witness to testify as to what happens when a person is found not guilty by reason of insanity. In addition, Middlebrooks contended “[t]he trial court erred in restricting the testimony of [her] diagnosing psychiatrist,” an employee of the Department of Veterans’ Affairs (“VA”), “without following the correct procedure” under federal regulations concerning the testimony of VA personnel in legal proceedings. In a related claim, Middlebrooks contended her “trial counsel was ineffective in failing to object to the limitation of [the witness’s] testimony by the [f]ederal [g]overnment and the [p]rosecutor.” Finding no reversible error, the Georgia Supreme Court affirmed. View "Middlebrooks v. Georgia" on Justia Law