Justia Georgia Supreme Court Opinion Summaries

A jury convicted Lawrence Rice of murdering Connie Mincher and her 14-year-old son, Ethan, and of burglary. The jury found multiple statutory aggravating circumstances related to each of the murders and recommended a death sentence for each of the murders, which the trial court imposed. Upon our review of the record, the Supreme Court concluded that there were no errors at trial, and that the evidence presented was sufficient to authorize a rational trier of fact to find Rice guilty beyond a reasonable doubt on all counts. View "Rice v. Georgia" on Justia Law

Eloise Collins died in 2006. In July 2007, Lydia Swain, Collins’ goddaughter, filed a petition to probate two instruments alleged to be Collins’ will: an unwitnessed letter written in 1999 detailing how Collins wanted her property distributed after her death and a partially filled-out commercial will form that, while properly witnessed, did not address distribution of property. A number of Collins’ first cousins (collectively, Lee) challenged the will and the trial court initially granted judgment on the pleadings in their favor, finding that the two documents could not form a valid will. Swain appealed and the Supreme Court held that there was a genuine issue of material fact as to whether the two documents, considered together, created a valid will. On remand, a jury found that the two instruments were indeed “the true Last Will and Testament of Eloise Harley Collins.” Lee appealed, claiming that the trial court erred by failing to grant summary judgment or a directed verdict, improperly instructing the jury on the law regarding codicils, and refusing to include a number of requested instructions in its charge to the jury. Upon review, the Supreme Court disagreed and affirmed the trial court’s verdict in favor of Swain. View "Lee v. Swain" on Justia Law

Defendant John Dennis Woods appealed his convictions for malice murder, aggravated assault, possession of a firearm during the commission of a felony, and concealing the death of another, all in connection with the death of Travis Sauls. The evidence authorized the jury to find Woods guilty beyond a reasonable doubt of the crimes for which he was convicted, and the trial court found no ineffective assistance of counsel. However, after review of the record, the Supreme Court found that Defendant presented evidence that he suffered from a mental disease that could have produced a seizure causing a temporary delusion that Sauls posed a threat to his life, even though Sauls may not, in fact, have posed any immediate threat. Defendant filed a written request that the jury be instructed on the law regarding a verdict of not guilty by reason of insanity. During a charge conference, the trial court agreed to give that instruction, as well as certain other written instructions Defendant requested. The next day, immediately before argument, Defendant verbally requested that the jury be instructed on the law regarding self defense using pattern charges; but he had not submitted a written request for such an instruction. The State objected. The trial court stated that the instructions would remain as had been decided during the charge conference. Accordingly, the jury could not determine whether Defendant was suffering from a delusion that satisfied the legal definition without an understanding of what constituted an act that would have been justified, if the circumstances were as Defendant contended he believed them to be, without being instructed as to what conduct would constitute justification. Absent such an instruction, the jury was not provided “with the proper guidelines for determining guilt or innocence.” Accordingly, the Supreme Court concluded that Defendant must be afforded a new trial. View "Woods v. Georgia" on Justia Law

A jury convicted Winston Clay Barrett of malice murder and related crimes and recommended a death sentence for the murder after finding beyond a reasonable doubt the following statutory aggravating circumstances: the murder was committed while Barrett was engaged in the commission of an aggravated battery, and the murder was outrageously or wantonly vile, horrible, or inhuman in that it involved torture and an aggravated battery to the victim before his death and manifested the defendant's depravity of mind. The trial court denied Barrett's motion for new trial, and he appealed. Finding no error, the Supreme Court affirmed Barrett's conviction and sentence. View "Barrett v. Georgia" on Justia Law

Appellant Justin Brown was convicted of felony murder, aggravated battery, kidnapping with bodily injury, aggravated assault, and burglary in connection with the shooting death of J.R. Morrow. Brown's motion for new trial was denied, and he appealed that decision and his conviction and sentence. On appeal, Brown asserted that: (1) the evidence was insufficient to sustain his convictions; (2) the State failed to prove the "asportation" requirement for kidnapping with bodily injury; (3) the State knowingly introduced false testimony in support of its case in chief; and (4) the trial court erred in failing to charge the jury concerning mere approval of an act and withdrawal from a conspiracy. Finding no error, the Supreme Court affirmed Brown's conviction. View "Brown v. Georgia" on Justia Law

The Supreme Court granted a writ of certiorari to the Court of Appeals in this case to determine whether the definition of "tangible evidence," as that term is used in OCGA 17-5-21 (a) (5), includes evidence gained by thermal imaging. Although the Court found that the Court of Appeals was incorrect in determining that the term "tangible evidence" encompasses the evidence at issue, it nonetheless affirmed the appellate court's judgment. In 2009, a University of Georgia police officer assigned to a drug task force, after receiving a tip from a confidential informant, investigated an individual who was suspected of growing marijuana. The warrant authorized the detective to "search and seize" the "[a]namolous heat loss occurring at the described premises . . . ." The Supreme Court concluded that the Court of Appeals erred when it concluded that "tangible evidence" as used in OCGA 17-5-21 (a) (5) was that which was not "testimony or verbal statements"; the term "tangible evidence" as used in the statute did not embrace the "amorphous heat loss" captured by the thermal imaging used here. Although the Court of Appeals noted that heat radiating from a building is "real and substantial, rather than imaginary, "[g]iving the word 'tangible' full effect, it appears that the General Assembly intended 'tangible evidence' to mean evidence that is essentially an object with material form that could be touched by a person. . .[t]hat meaning does not include the remotely-sensed heat at issue here." View "Brundige v. Georgia" on Justia Law

In case number S12A0649, Burke County, its Board of Commissioners, and various members of the Board, individually and in their official capacities appealed the superior court's grant of a writ of mandamus involving the obligation to maintain roads dedicated to the County. In case number S12X0650, Otis F. Askin, Sr., and Tiger, Inc. cross-appealed the failure of the superior court to grant certain other relief that Askin had requested. As to each appeal, the Supreme Court vacated the judgment of the superior court and remanded with direction. View "Burke County v. Askin" on Justia Law

Appellant Devon Sharif Doyle was convicted and sentenced for malice murder, several counts of aggravated assault, and possession of a firearm during the commission of a crime. He appealed asserting, inter alia, trial counsel was ineffective in failing to object to prosecutorial misconduct. Finding no error, the Supreme Court affirmed. View "Doyle v. Georgia" on Justia Law

Appellant Jill E. Eldridge (Wife) filed for divorce from appellee Joshua R. C. Eldridge (Husband) after more than seven years of marriage. Following a bench trial, the trial court issued a final judgment and decree of divorce in which it granted joint legal custody of the couple's two children to both parents and primary physical custody to Wife; ordered Husband to pay $1379 per month in child support; assigned to Wife responsibility for her student loans; and adopted its own parenting plan. The Supreme Court granted Wife's application for discretionary review and concluded that the trial court erred: (1) in its determination of child support by failing to make mandatory written findings in granting a deviation and in applying an incorrect conversion factor in calculating Wife's monthly child care costs and (2) in adopting a parenting plan that failed to specify when Husband's weekend visitation begins and ends. Accordingly, the Court reversed in part, affirmed in part, and remanded with direction. View "Eldridge v. Eldridge" on Justia Law

The trial court held Randy Horn (Husband) in contempt for violating his divorce decree with Brandie Shepherd (Wife) and ordered him incarcerated until he purged himself of the contempt. Husband appealed, and the Supreme Court concluded that the trial court erred in requiring him to pay attorney fees associated with the contempt proceeding in order to purge the contempt; the Court therefore reversed that small portion of the trial court's judgment. Husband's "many other enumerations of error" were without merit, and the Court affirmed the remainder of the judgment. View "Horn v. Shepherd" on Justia Law