Justia Georgia Supreme Court Opinion Summaries

The case concerns a man who was convicted of malice murder and other offenses following the shooting deaths of his wife and his stepson. The events began with a family argument at a baseball game, which escalated when the defendant was punched by his stepdaughter after he pushed his wife. Two days later, the defendant purchased a handgun. On the day of the shootings, the defendant’s stepdaughter and her husband became concerned after being unable to reach her mother. When they went to the mother’s home, they discovered her dead in the basement. As they were leaving, they encountered the defendant returning home. The stepdaughter’s husband fired at the defendant’s car, and after a series of events, the defendant pursued and fatally shot the husband during an exchange of gunfire. The defendant was later arrested at the scene.A Gwinnett County grand jury indicted the defendant on multiple counts, including malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. At trial in the Superior Court of Gwinnett County, the jury found him guilty of malice murder for his wife’s death, voluntary manslaughter for his stepson’s death, and both firearm offenses. The court sentenced him to life without parole plus additional consecutive terms. The defendant’s motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the sufficiency of the evidence and the admission of certain expert testimony. The court held that the evidence was sufficient to support the convictions, as a rational jury could find the defendant guilty beyond a reasonable doubt. The court also found that any error in admitting the expert’s testimony was harmless. The convictions and sentences were affirmed. View "MACK v. THE STATE" on Justia Law

Anthony Scott was convicted of malice murder and related charges after shooting and killing his wife, Cathy Scott, following marital discord and suspicions of infidelity. On the evening of March 14, 2011, a neighbor heard gunshots and witnessed Scott admit to killing his wife, then saw Scott shoot her again. Scott called 911 and confessed to law enforcement, stating he shot Cathy because of her adultery. Ballistics confirmed the bullets were fired from Scott’s pistols. At trial, Scott testified he “snapped” after a confrontation about a photo on Cathy’s phone and claimed not to remember the shooting, though he acknowledged shooting her.A Lee County grand jury indicted Scott, and in October 2012, a jury found him guilty on all counts. He was sentenced to life in prison for malice murder, with additional probation for the firearm charge. The trial court merged the aggravated assault and felony murder counts into the malice murder conviction, with the felony murder count vacated by law. Scott filed a timely motion for new trial, which was amended by new counsel in 2023. After several continuances, the trial court denied the amended motion for new trial in January 2025, finding Scott’s claims lacked credible supporting evidence.The Supreme Court of Georgia reviewed Scott’s appeal, which argued ineffective assistance of counsel for failing to pursue an insanity defense and challenged the denial of further continuances to obtain supporting evidence. The Court held that the trial court did not abuse its discretion in denying additional continuances, given the multiple delays already granted. The Court further held that Scott failed to show prejudice under Strickland v. Washington, as he presented no credible or independent evidence of insanity at the time of the crime. The judgment of the trial court was affirmed. View "SCOTT v. THE STATE" on Justia Law

The case concerns a defendant who was convicted of three counts of malice murder and several related firearm offenses after the shooting deaths of three individuals in Savannah, Georgia. The defendant, a member of a criminal street gang, admitted to shooting the victims but claimed he acted in self-defense, citing a perceived threat during a gathering where all parties were armed and under the influence of drugs. Physical evidence, including ballistics and fingerprints, linked the defendant to the crime scene, and he was apprehended after a high-speed chase in a vehicle rented by one of the victims. The defendant gave multiple recorded statements to law enforcement, admitting to the shootings and describing his belief that he was in danger.A Chatham County jury found the defendant guilty on all counts, and the trial court imposed three concurrent life sentences without parole for the murders, along with additional sentences for firearm offenses. The defendant’s motion for a new trial was denied by the trial court. On appeal, the defendant argued that the trial court erred by not instructing the jury on voluntary manslaughter, that his trial counsel was ineffective in several respects, that cumulative errors warranted a new trial, and that his post-conviction counsel was also ineffective.The Supreme Court of Georgia reviewed the case and rejected all of the defendant’s claims. The court held that there was no plain error in failing to instruct the jury on voluntary manslaughter, as the evidence did not show sufficient provocation. The court also found no ineffective assistance of counsel, either at trial or post-conviction, and determined that any assumed errors did not prejudice the outcome. The court affirmed the convictions and sentences. View "MARROW v. THE STATE" on Justia Law

The case concerns a woman who was convicted of felony murder and aggravated assault following the shooting death of her husband in 2008. The incident occurred during a period of marital discord and financial stress. The defendant called 9-1-1, initially reporting that her husband had shot at her and then shot himself. However, physical evidence and witness testimony, including that of her young daughter, suggested multiple gunshots and circumstances inconsistent with suicide. The defendant gave varying accounts to law enforcement, at times claiming self-defense, accident, or that her husband shot himself.After her initial conviction in the Superior Court of Coweta County, the Georgia Supreme Court affirmed the verdict. Subsequent habeas proceedings in state and federal courts led to a finding by the United States Court of Appeals for the Eleventh Circuit that her appellate counsel had been ineffective, resulting in an order for a new trial. The trial court set aside her conviction, and at the 2019 retrial, a jury again found her guilty of felony murder and aggravated assault. The trial court merged the assault count for sentencing and imposed a life sentence. The defendant’s motion for a new trial was denied, and she appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed several evidentiary issues. It held that the trial court erred in admitting evidence of the defendant’s prior acts of violence against ex-husbands to show motive, as this constituted improper propensity evidence. However, the court found that the same evidence was properly admitted to show intent and absence of mistake or accident. The court also held that the admission of the daughter’s recorded statements was either proper or, if erroneous, harmless. The court concluded that any cumulative error did not deprive the defendant of a fair trial and affirmed the conviction. View "HALL v. THE STATE" on Justia Law

The case concerns Dominique Richardson, who was convicted of malice murder and related offenses following the shooting death of Taylor Holcombe. Richardson and Holcombe were in a relationship, and on the day of the incident, Richardson, Holcombe, and Cedric Porter spent time together, including picking up Porter and stopping at a gas station. Porter testified that Richardson suddenly pulled a gun on Holcombe while driving, after which Holcombe fled the car and Richardson shot her. Richardson then threatened Porter and later took steps to cover up the crime, including burning Holcombe’s car. Evidence at trial included Porter’s eyewitness account, testimony from a medical examiner, cell phone location data, and statements from a friend, Dontavious Davis, to whom Richardson allegedly confessed.A DeKalb County jury found Richardson guilty on all counts, and the trial court sentenced him to life without parole for malice murder, with additional time for firearm possession. The aggravated assault count merged, and the felony murder count was vacated by operation of law. Richardson’s motion for a new trial was denied by the trial court, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Richardson’s claims that the evidence was insufficient and that the trial court erred in admitting an audio recording of a witness’s prior statement. The Court held that the evidence, including direct eyewitness testimony and corroborating evidence, was sufficient to support the convictions under both federal and Georgia law. The Court also found that any error in admitting the audio recording was harmless given the strength of the other evidence. The Supreme Court of Georgia affirmed Richardson’s convictions. View "RICHARDSON v. THE STATE" on Justia Law

The case concerns a shooting that occurred in Bibb County, Georgia, in July 2021. The defendant called 911 and reported that he had shot his roommate and friend. When law enforcement arrived, the defendant made several unsolicited statements admitting to the shooting and expressing that he had wanted to kill the victim. Physical evidence and testimony established that the victim was shot in the back from a distance, and the autopsy confirmed homicide as the cause of death. The State also introduced evidence of the defendant’s prior felony conviction.A Bibb County grand jury indicted the defendant for malice murder, felony murder predicated on possession of a firearm by a convicted felon, and possession of a firearm by a convicted felon. At trial in the Superior Court of Bibb County, the jury found the defendant guilty on all counts. The trial court sentenced him to life in prison for malice murder, merged the possession count into the felony murder count, and then vacated the felony murder count. The defendant filed a motion for new trial, which was denied after a hearing. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the defendant’s claim that his trial counsel was ineffective for allegedly failing to properly advise him of his right to testify. The Court held that the record did not show that counsel advised the defendant not to testify, nor that any such advice would have been unreasonable. The Court found no evidence of deficient performance by counsel and concluded that the defendant failed to meet his burden under Strickland v. Washington. Accordingly, the Supreme Court of Georgia affirmed the judgment. View "WOODS v. THE STATE" on Justia Law

The case concerns the fatal shooting of Jamaal Smith during an attempted robbery at an apartment complex in Warner Robins, Georgia, on November 16, 2020. On the night of the incident, Smith and two friends, Moss and Brown, accompanied Terrence Rouse to the complex, where Rouse intended to buy marijuana. Testimony established that Rouse, armed with a gun, persuaded Smith to accompany him to an apartment, where a confrontation and shooting occurred. Smith was shot and later died at the hospital. Moss and Brown, who were present at the scene, identified Rouse as the perpetrator. Physical evidence included a handprint on the car used to transport Smith and ballistics evidence, though the latter was inconclusive as to the fatal bullet’s source.After the incident, Rouse was indicted on multiple counts, including three counts of felony murder predicated on different felonies, as well as related charges. He was tried individually in the Superior Court of Houston County and found guilty on all counts except for possession of a firearm by a convicted felon, which was nolle prossed. The trial court sentenced Rouse to life with the possibility of parole on one count of felony murder, merging the remaining counts. Rouse’s motion for a new trial was denied.On appeal to the Supreme Court of Georgia, Rouse argued that the evidence was insufficient to support his conviction, that his trial counsel was ineffective for not publishing certain jail letters to the jury, and that the trial court erred in admitting testimony about a prior drug deal. The Supreme Court of Georgia held that the evidence was sufficient, counsel’s actions were reasonable trial strategy, and the evidentiary rulings were not an abuse of discretion. The court affirmed the conviction and sentence. View "ROUSE v. THE STATE" on Justia Law

In this case, the defendant and the victim lived in separate rooms at the same motel. The defendant testified that a dispute arose after he refused to sell marijuana to the victim’s girlfriend, leading to several tense encounters between the defendant and the victim. On the day of the incident, the defendant, armed with a gun, approached the victim’s room under the pretense of checking on him. An argument ensued, during which the defendant claimed to feel threatened by the victim, who was larger and allegedly aggressive with a broom. The defendant shot the victim multiple times, resulting in the victim’s death. A witness in the room described the conversation as initially calm but escalating, and testified to hearing gunshots and seeing the defendant leave. The defendant was later arrested, and the murder weapon was recovered.A DeKalb County grand jury indicted the defendant for malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. After a jury trial in the Superior Court of DeKalb County, the defendant was found guilty on all counts. The trial court sentenced him to life imprisonment for malice murder and a consecutive five-year term for the firearm offense, with the remaining counts merged or vacated. The defendant’s motion for new trial, and an amended motion through new counsel, were denied.The Supreme Court of Georgia reviewed the case. The court held that the trial court did not err in refusing to instruct the jury on voluntary manslaughter, as there was no evidence the defendant acted out of sudden, violent passion rather than fear or self-defense. The court also found no plain error in the prosecutor’s reference to the defendant’s invocation of his right to counsel during interrogation, as any potential error was harmless given the strong evidence of guilt. Finally, the court ruled that the defendant’s ineffective assistance claims were waived because they were not raised at the earliest practicable moment. The convictions were affirmed. View "HENDERSON v. THE STATE" on Justia Law

In this case, the defendant was charged in connection with the armed robbery and murder of an individual named Deontavious Wright. The incident occurred when three men, including the defendant, entered an apartment where Deontavious lived, along with several other people and two young children. One of the men, Rucker, held Deontavious at gunpoint, demanded drugs and money, and ultimately shot Deontavious multiple times after taking his possessions. The defendant was identified by three eyewitnesses who recognized him despite his mask, based on his clothing, physical features, and voice. Cell phone location data also placed the defendant near the scene at the relevant time. The defendant and his alibi witness testified that he was elsewhere during the crime.The Superior Court of Fulton County conducted a joint jury trial for the defendant and his co-defendants. The jury found the defendant guilty of felony murder predicated on home invasion, armed robbery, aggravated assault, cruelty to children, and firearm possession offenses, but acquitted him of malice murder and one count of aggravated assault. The court sentenced him to life imprisonment and additional terms for the other convictions. The defendant filed a motion for a new trial, which was denied, and then appealed.The Supreme Court of Georgia reviewed the case. It held that the evidence was constitutionally sufficient to support the convictions, as the jury was entitled to credit the eyewitness identifications and the corroborating cell phone evidence. The Court also found that the trial court did not err in admitting a co-defendant’s non-testimonial statements under Bruton v. United States, as those statements were not made for prosecutorial purposes. Finally, the Court held that the trial court did not abuse its discretion in denying the defendant’s motion to sever his trial from his co-defendants. The Supreme Court of Georgia affirmed the convictions. View "IVORY v. THE STATE" on Justia Law

The case concerns the fatal stabbing of Jason Cason, Jr. on November 10, 2022. Cason lived with Gary Mack, who testified that on the day of the incident, George Sharrod Johns, a friend and frequent visitor, entered Cason’s bedroom. Mack heard Cason plead, “[D]on’t hit me no more,” and soon after, saw Johns leave the apartment alone. Mack discovered Cason unresponsive and covered in blood, then saw Johns attempt to re-enter the apartment before leaving the area. Police later found bloodstains in Johns’s apartment matching Cason’s DNA. Forensic evidence established that Cason suffered 27 stab wounds, including defensive injuries, and died rapidly from chest wounds.A Fulton County grand jury indicted Johns for malice murder, felony murder, and aggravated assault. After a jury trial in December 2023, Johns was convicted on all counts. The trial court sentenced him to life in prison for malice murder, merging or vacating the other counts. Johns filed a motion for new trial, which was denied by the Superior Court of Fulton County in September 2024. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Johns’s claims that the evidence was insufficient, that the trial court erred in admitting certain autopsy photographs, and that his Confrontation Clause rights were violated by the testimony of a medical examiner who did not perform the autopsy. The court held that the evidence was constitutionally sufficient to support the conviction, the trial court did not abuse its discretion in admitting the autopsy photographs, and there was no Confrontation Clause violation because the testifying expert provided an independent opinion rather than relaying another’s findings. The court affirmed Johns’s convictions and sentence. View "JOHNS v. THE STATE" on Justia Law