Justia Georgia Supreme Court Opinion Summaries

Leon Lamar Tripp was arrested on May 23, 2017, in connection with the disappearance of Latania Janell Carwell, his stepdaughter. Janell's remains were found on March 8, 2018, leading to Tripp's indictment for murder, kidnapping, and other crimes. Tripp was interviewed multiple times by law enforcement and later sought to suppress these custodial statements. The trial court granted in part and denied in part Tripp's motions to suppress.The trial court ruled that Tripp's statements from May 23, 2017, and June 2, 2017, were admissible, finding they were made voluntarily and after a proper Miranda waiver. However, the court suppressed statements made after June 8, 2017, including those from a June 9, 2017, interview, concluding that Tripp had invoked his right to counsel during this interview. The State appealed the suppression of the June 9 interview, while Tripp cross-appealed the admissibility of the May 23 and June 2 interviews and the partial suppression of the June 9 interview.The Supreme Court of Georgia reviewed the case and affirmed the trial court's decision regarding the admissibility of the May 23 and June 2 interviews, agreeing that Tripp had voluntarily waived his Miranda rights. However, the court reversed the suppression of the entire June 9 interview, determining that Tripp's statements before 3:37 p.m. were spontaneous and not elicited by interrogation, and thus should not have been suppressed. The court held that only the statements made after 3:37 p.m., when Tripp's attorney advised him to remain silent, were inadmissible. View "THE STATE v. TRIPP" on Justia Law

Jasmine Williams was found guilty of malice murder in connection with the shooting death of Gregory Swinson. The incident occurred on or about September 16, 2017, and Swinson succumbed to his injuries a few days later. Williams and Swinson had a tumultuous relationship, and on the night of the incident, they had been drinking and arguing. Swinson had visible injuries, and after a confrontation at Williams's house, she shot him. Williams claimed the shooting was accidental.The Coffee County grand jury indicted Williams for felony murder and malice murder. In October 2018, a jury found her guilty on both counts, and the trial court sentenced her to life in prison without the possibility of parole for malice murder, with the felony murder count vacated by operation of law. Williams filed a motion for a new trial, which was denied by the trial court. She then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the case and addressed several arguments raised by Williams. First, the court found no abuse of discretion in the trial judge's decision not to recuse himself, as the conversation in question did not involve the pending trial and did not create an appearance of impropriety. Second, the court held that the trial court did not err in refusing to charge the jury on self-defense, accident, and voluntary manslaughter, as the evidence did not support these defenses. Finally, the court concluded that Williams's trial counsel was not constitutionally ineffective for withdrawing the request to charge on defense of habitation, as Williams failed to show that the outcome of the trial would have been different had the charge been given.The Supreme Court of Georgia affirmed the trial court's judgment, upholding Williams's conviction and sentence. View "THE STATE v. LEVERETTE" on Justia Law

Ammon Sumrall was convicted in October 1992 by a DeKalb County jury of felony murder, armed robbery, and other crimes related to the shooting death of Wade Barrett, Jr. on April 7, 1991. He was sentenced to two consecutive life sentences plus five additional years. Over 30 years later, Sumrall filed a pro se petition in the Superior Court of DeKalb County seeking retroactive first-offender treatment based on an amendment to OCGA § 42-8-66. He also filed a motion to declare the statute unconstitutional.The trial court initially dismissed Sumrall’s petition and motion, but later vacated this order and issued an amended order. The amended order dismissed the petition for failing to obtain the necessary consent from the prosecuting attorney and denied the motion to declare the statute unconstitutional, citing a lack of standing and insufficient supporting arguments.The Supreme Court of Georgia reviewed the case and affirmed the trial court’s decisions. The court held that Sumrall failed to meet the statutory requirement of obtaining the prosecuting attorney’s consent before filing his petition for retroactive first-offender treatment. The court also found no merit in Sumrall’s argument that the prosecuting attorney’s inaction constituted implied consent. Additionally, the court upheld the trial court’s denial of Sumrall’s motion to declare OCGA § 42-8-66 (a) (1) unconstitutional, concluding that Sumrall did not demonstrate a clear and palpable conflict with the Georgia or United States Constitutions. The court emphasized that the statute did not deprive Sumrall of his right to access the courts or to be heard. View "Sumrall v. State" on Justia Law

Jarrod James Hayes was convicted of malice murder and other crimes related to the shooting death of Zedekiah Jones. Hayes argued that the trial court erred in denying his motion to suppress three firearms found at his home, which he disclosed without receiving Miranda warnings. He also claimed ineffective assistance of counsel, improper admission of a witness's video statement, refusal to bifurcate charges, and failure to instruct the jury on voluntary manslaughter and mutual combat.A Douglas County grand jury indicted Hayes on multiple charges, including malice murder and possession of a firearm by a convicted felon. The marijuana possession charge was dropped, and Hayes was found guilty on all remaining charges. He was sentenced to life in prison without parole for malice murder and additional concurrent terms for the weapons charges. Hayes's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case and held that the firearms were admissible because Hayes's statement about their location was voluntary, despite the lack of Miranda warnings. The court also found no merit in Hayes's other claims. The court concluded that the trial court did not abuse its discretion in admitting the witness's prior inconsistent statement, denying the motion to bifurcate charges, or refusing to give jury instructions on voluntary manslaughter and mutual combat. The court also determined that any errors by trial counsel did not result in prejudice sufficient to undermine confidence in the trial's outcome. Consequently, the Supreme Court of Georgia affirmed Hayes's convictions and sentences. View "Hayes v. State" on Justia Law

Lewarner Jaron Scott was convicted of murder and other crimes related to the shooting death of Kevin Compton. The incident occurred on July 12, 2014, at a nightclub in Kennesaw, Georgia. A bottle was thrown, injuring Scott’s friend, Jawaree Hill, which led to an altercation. Compton, along with his friends Brandon McMurtry and McKinley Bain, decided to leave the club. As they were driving out of the parking lot, gunshots were fired, and Compton was fatally shot in the head. Witnesses identified a man with dreadlocks and a blue shirt carrying a gun before and after the shooting. Scott was later identified as the man seen with the gun and driving a gray Dodge Neon.A Cobb County grand jury indicted Scott on multiple charges, including malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. In August 2015, a jury found Scott guilty on all counts. The trial court sentenced him to life in prison plus additional consecutive sentences for other charges. Scott’s trial counsel filed a motion for a new trial, which was later amended by his post-conviction counsel. The trial court denied the motion for a new trial in August 2023, and Scott’s counsel filed a timely notice of appeal.The Supreme Court of Georgia reviewed the case and concluded that the evidence was sufficient to support Scott’s convictions beyond a reasonable doubt. The court noted that the jury was authorized to reject alternative hypotheses presented by Scott and found that the circumstantial evidence, including witness testimonies and forensic evidence linking the spent casings to Scott’s gun, supported the verdict. The court affirmed the judgment, upholding Scott’s convictions and sentences. View "Scott v. State" on Justia Law

Andrew Troutman was convicted of malice murder for the stabbing death of Earl Clemons. The incident occurred in January 2014, and Troutman was indicted on charges of malice murder, felony murder, and aggravated assault. The case involved a pre-trial appeal where the trial court's decision to suppress a statement made by Troutman to the police was partially affirmed and partially reversed by the Supreme Court of Georgia. At trial in August 2019, the jury found Troutman guilty on all counts, and he was sentenced to life with the possibility of parole. Troutman filed a motion for a new trial, which was denied, leading to this appeal.The trial court's decision was based on evidence including threats made by Troutman against Clemons, Troutman's presence at the crime scene, and his confessions to his uncle and former girlfriend. The jury also heard about a fake DeVry student ID found in Troutman's room and his inconsistent statements to the police. The trial court's suppression of part of Troutman's confession did not affect the sufficiency of the evidence.The Supreme Court of Georgia reviewed the case and found the evidence constitutionally sufficient to support the conviction. The court held that OCGA § 24-14-6, which pertains to circumstantial evidence, did not apply because there was direct evidence of Troutman's guilt. Claims of prosecutorial misconduct were either not preserved for review or resolved in Troutman's favor. The court also found that Troutman did not prove prejudice from his claims of ineffective assistance of counsel, including the decision to present an alibi defense and the failure to object to certain prosecutorial comments during closing arguments.The Supreme Court of Georgia affirmed the trial court's judgment, concluding that the evidence was sufficient to support the conviction and that Troutman did not demonstrate that any alleged errors by his trial counsel affected the outcome of the trial. View "Troutman v. State" on Justia Law

Kaylon Janard Jiles was found guilty of felony murder and other crimes related to the shooting death of Eris Fisher. Fisher and his associate, Laura Griffin, had been buying and selling cocaine together. Fisher contacted Jiles to purchase cocaine, but after receiving it, Fisher complained that the weight was off. Jiles agreed to deliver more cocaine to Fisher. When Fisher arrived at the motel parking lot to meet Jiles, Jiles and two other men approached and shot Fisher. Fisher's wife, Maryanne Crawford, and Griffin witnessed the shooting. Crawford initially lied to officers about the motive for the shooting, and Griffin disposed of a gun found near Fisher's body.The DeKalb County grand jury indicted Jiles and Traquan McLeod for multiple charges, including malice murder and felony murder. McLeod pleaded guilty to reduced charges, while Jiles went to trial. The jury acquitted Jiles of malice murder and gang activity but found him guilty of felony murder and other charges. The trial court sentenced Jiles to life in prison without parole. Jiles filed a motion for a new trial, which was denied, leading to this appeal.The Supreme Court of Georgia reviewed the case. Jiles argued that the trial court erred by not instructing the jury on accomplice corroboration and that his trial counsel was ineffective. The court found no plain error in the jury instructions and determined that Jiles's counsel's performance was not deficient. The court also found that any presumed errors did not likely affect the trial's outcome. The Supreme Court of Georgia affirmed Jiles's convictions, concluding that the cumulative prejudice from the alleged errors did not warrant a new trial. View "Jiles v. State" on Justia Law

John Deangelo Sharkey was convicted of malice murder and armed robbery in connection with the shooting death of Dominique Barker. The crimes occurred on December 6, 2017. Sharkey was indicted by a Clayton County grand jury on February 8, 2018, and a jury trial was held from January 13 to 16, 2020. The jury found Sharkey guilty on all counts, and he was sentenced to life in prison without the possibility of parole for malice murder, plus 20 years consecutive for armed robbery. Sharkey filed a motion for a new trial, which was denied by the trial court.Sharkey appealed, challenging the sufficiency of the evidence, the exclusion of a video recording showing a four-year-old child identifying another man in a photo lineup, and claiming ineffective assistance of counsel for failing to admit the video under the child-hearsay statute. The trial court had excluded the video, and Sharkey argued that his counsel was ineffective for not taking steps to admit it.The Supreme Court of Georgia reviewed the case and found that the evidence was more than sufficient to support Sharkey's convictions. The court noted that the evidence against Sharkey was strong, including eyewitness identifications and the presence of his cell phone at the crime scene. The court also held that any error in excluding the video recording was harmless and that any deficient performance by trial counsel was nonprejudicial. The court affirmed Sharkey's convictions, concluding that there was no reasonable probability that the outcome of the trial would have been different if the video had been admitted. View "Sharkey v. State" on Justia Law

Adrian Darnyell Weston was convicted of malice murder for the shooting death of Alex Tolbert. The incident occurred on January 23, 2021, at a hotel in Madison, where Tolbert was found shot 11 times. Investigators collected fourteen .22-caliber shell casings and three bullets from the scene. Weston was identified as a person of interest due to a history of conflict with Tolbert, including a stabbing incident in 2019. On the day of the murder, Weston was overheard saying he would kill Tolbert and was seen leaving with a gun. Shell casings from the crime scene matched those found at a residence where Weston stayed. Weston fled the state and was later arrested in Kansas.A Morgan County grand jury indicted Weston for malice murder, felony murder, and aggravated assault in March 2021. In November 2022, a jury found Weston guilty on all counts. The trial court sentenced him to life in prison without parole for malice murder, with the other counts merging or being vacated. Weston filed a motion for a new trial, which was denied by the trial court in April 2024. He then filed a timely notice of appeal.The Supreme Court of Georgia reviewed the case and affirmed the conviction. The court held that the evidence, though circumstantial, was sufficient to support the conviction under Georgia law. The court noted that the jury is responsible for resolving evidentiary conflicts and assessing witness credibility. The court also found that the trial court properly exercised its discretion in denying Weston’s motion for a new trial on the general grounds, as it had considered the evidence, witness credibility, and the weight of the evidence. The court concluded that the evidence presented at trial was sufficient to exclude every reasonable hypothesis other than Weston’s guilt. View "Weston v. State" on Justia Law

In December 2017, Roger Tashawn Mills was involved in the shooting death of Masuto Garrett. Mills and his co-defendant, Mosas Bolar, were indicted on multiple charges, including malice murder and felony murder. Mills was initially convicted on all counts, but his convictions were reversed on appeal due to the improper removal of a juror. Mills was retried and found guilty of felony murder and other related charges. He was sentenced to life without parole plus an additional five years for firearm possession.During the retrial, the jury found Mills guilty of several charges, including felony murder and aggravated assault, but acquitted him on others. Mills filed a motion for a new trial, which was denied, leading to the current appeal. Mills argued that the evidence was insufficient to disprove his justification defense and that the trial court erred in admitting other-acts evidence.The Supreme Court of Georgia reviewed the case and held that the evidence was sufficient to support Mills' convictions. The court found that the jury was entitled to reject Mills' justification defense based on the evidence presented, including witness testimony and forensic analysis. The court also held that the trial court did not commit plain error in admitting other-acts evidence, as it was relevant to show Mills' motive and gang affiliation, and its probative value was not substantially outweighed by undue prejudice.The Supreme Court of Georgia affirmed Mills' convictions, concluding that the State had met its burden of disproving Mills' justification defense beyond a reasonable doubt and that the trial court did not err in its evidentiary rulings. View "Mills v. State" on Justia Law