Justia Georgia Supreme Court Opinion Summaries

Patrick Satterfield was convicted by jury of felony murder and other crimes in connection with the death of Richard Boynton. On appeal, Satterfield contended the evidence was insufficient to support the verdicts and that his trial counsel was ineffective. Finding no reversible error, the Georgia Supreme Court affirmed his convictions. View "Satterfield v. Georgia" on Justia Law

Appellant Roshun Gray was convicted of malice murder and two firearm offenses in connection with the 2012 shooting death of Ferderian Bennett. On appeal, Appellant contended he was legally incompetent to stand trial and that his trial counsel provided ineffective assistance by failing to investigate his incompetency. Finding both of those claims as meritless, the Georgia Supreme Court affirmed. View "Gray v. Georgia" on Justia Law

Antavian Love was convicted of malice murder and other crimes in connection with the shooting death of Enrique Trejo. On appeal, Love, who was 16 years old at the time the crimes were committed, argued the trial court erred in denying the motion to suppress his statements to law enforcement and in sentencing him as a juvenile to serve life without parole. Finding no reversible error, the Georgia Supreme Court affirmed his convictions. View "Love v. Georgia" on Justia Law

Otis Hill shot Christina and Marshall Wellington when they were unable to pay a drug debt. Christina died; Marshall survived but lost an eye. Hill and Aviance Marshall, who drove Hill and the Wellingtons to the location of the shooting, were charged with malice murder, attempted murder, kidnapping, and related offenses. Hill was convicted of kidnapping and murdering Christina, kidnapping, battering, and attempting to murder Marshall, and a weapons charge. On appeal, Hill argued the evidence was insufficient as to kidnapping. In addition, Hill contended the trial court erred: in using a deficient master jury list; in failing to determine whether a juror was proficient in English; in instructing the jury regarding note taking; in admitting evidence of cell site location information, the effects of cocaine on memory, and witness intimidation; in excluding evidence of the maximum penalty Aviance faced; in instructing the jury regarding the reasonable-doubt standard; and in denying his motion for a new trial on the general grounds. Hill also claimed he received ineffective assistance of counsel. The Georgia Supreme Court found none of Hill's enumerations of error and affirmed, but vacated in part to correct sentencing errors. View "Hill v. Georgia" on Justia Law

Anthony Lumpkin and Eddie Green were convicted by jury of murder and other offenses in connection with the shooting death of Nicholas Jackson II. Both appellants argued the trial court erred by denying their motions to suppress evidence seized during a traffic stop. In addition, Lumpkin challenged the sufficiency of the evidence presented against him on the armed robbery count and the felony murder count predicated on armed robbery, and Green argued the trial court erred by not admitting certain evidence pursuant to OCGA 24-8-804. Finding no reversible error, the Georgia Supreme Court affirmed conviction, but vacated in part to correct a sentencing error with respect to Lumpkin. View "Lumpkin v. Georgia" on Justia Law

Appellant James Lowery challenged his 2017 conviction for felony murder and other crimes in connection with the death of Montgomery County, Georgia Sheriff Ladson O’Connor, who was killed in a vehicular accident while pursuing Appellant. Appellant argued the evidence was insufficient to support his felony murder conviction; the trial court failed to apply the correct standard in denying his motion for new trial on the general grounds; that his pretrial statements to investigators were inadmissible because they were not knowingly and voluntarily made; and that the trial court erred in excluding evidence of Sheriff O’Connor’s character. Finding no reversible error, the Georgia Supreme Court affirmed. View "Lowery v. Georgia" on Justia Law

Thomas Edvalson was tried by jury and found guilty of 22 counts of sexual exploitation of children, for possession of 11 digital images depicting a minor engaged in sexually explicit conduct. With respect to each digital image, he was found guilty of both possession and possession with intent to distribute. At sentencing, the trial court merged the "simple" possession counts under OCGA 16-12-100(b)(8) into the counts of possession with intent to distribute under subsection (b)(5), and sentenced Edvalson on the remaining 11 counts to a total of 60 years, with 19 to be served in prison. Edvalson appealed, asserting, among other enumerations of error, that the trial court erred in failing to merge his convictions into a single count. The Court of Appeals affirmed in an unpublished opinion, concluding that OCGA 16-12-100(b)(5) permitted a defendant to be separately convicted and sentenced for each of the images in his possession. The Georgia Supreme Court granted review to consider whether the Court of Appeals erred in failing to merge the remaining 11 convictions under (b)(5) into a single conviction. In accordance with Coates v. Georgia, 818 SE2d 622 (2018), the Court concluded the plain language of OCGA 16-12-100(b)(5), interpreted in the context of the entire statute, was unambiguous and permitted only one prosecution and conviction for a single act of possession of child pornography, regardless of the number of images depicted. The Court therefore reversed the Court of Appeals and remanded the case for further proceedings. View "Edvalson v. Georgia" on Justia Law

Antonio Wallace was tried by a jury and convicted of the murder of Leroy O’Hara. Wallace appealed, claiming: (1) the evidence was insufficient to sustain his conviction; (2) the trial court erred when it denied his motion for new trial on the general grounds; and (3) that he was denied the effective assistance of counsel. The Georgia Supreme Court found no merit in these claims, and affirmed. View "Wallace v. Georgia" on Justia Law

Upon retrial, appellant Ronald Fisher was found guilty of malice murder and related crimes in connection with the shooting death of Derek Cullins. In this appeal, Fisher contended the evidence presented at his retrial was insufficient to support his convictions because the only witness to identify him as the shooter, David Lewis, was an accomplice. Further, Fisher argued the trial court erred by allowing the lead detective to testify that Lewis was not an accomplice, and that his trial counsel provided ineffective assistance by failing to object to the prosecutor’s closing argument. Finding no reversible error, the Georgia Supreme Court affirmed. View "Fisher v. Georgia" on Justia Law

Johnathan Ellison was convicted of malice murder for the stabbing death of Antwane Hyatte. Ellison appealed, arguing the trial court erred in admitting DNA evidence obtained from a buccal swab performed on him without a warrant while he was in custody. He argued that the admission of that evidence violated his constitutional rights because he did not knowingly and voluntarily consent to the buccal swab, and he was not given any Miranda-type warning. The Georgia Supreme Court determined the DNA evidence obtained from Ellison’s buccal swab did not match any of the DNA found at the crime scene or inculpate him in any other way, thus its admission was harmless beyond a reasonable doubt. The Court therefore affirmed. View "Ellison v. Georgia" on Justia Law