Justia Georgia Supreme Court Opinion Summaries

Articles Posted in Georgia Supreme Court
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Defendant was convicted of two counts of murder and related crimes in connection with the shooting deaths of two victims. Defendant appealed the denial of his motion for a new trial, alleging reversible error in certain jury instructions and in the trial court's failure to merge several of his convictions. The court found no error in the jury charge but vacated one count of aggravated assault, which should have been merged into the malice murder conviction. View "Ortiz v. State" on Justia Law

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Defendant appealed his conviction for malice murder, felony murder, aggravated assault, and tampering with evidence. Defendant contended that the evidence was insufficient to support the verdict and the trial court erred by admitting similar transaction evidence. The court held that the evidence was sufficient to enable the jury to find defendant guilty of the crimes for which he was convicted beyond a reasonable doubt. The court also held that the trial court did not err in admitting evidence of defendant's prior conviction for arson where the State offered the evidence to show defendant's bent of mind or course of conduct in using escalating degrees of violence toward women. Accordingly, the court affirmed the judgment. View "Muhammad v. State" on Justia Law

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Defendant was convicted of the malice murder and aggravated assault of his wife and sentenced to life in prison. Defendant appealed the denial of his motion for a new trial, asserting that the trial court erred by admitting similar transaction evidence and evidence of statements made by the victim regarding prior difficulties. The court concluded that any prejudice from the age of the similar transactions evidence at issue was outweighed by the probative value of the evidence. The court also concluded that there was no error in admitting the testimony of defendant's cell-mate because the evidence was sufficient to establish the required similarity between the charged crimes and the attack on the cellmate and was probative of defendant's bent of mind and course of conduct. The court did not err in permitting several witnesses to testify about the statements the victim made pertaining to prior difficulties between defendant and the victim where the hearsay testimony was either admissible under the necessity exception to the hearsay rule or its admission constituted harmless error. Accordingly, the court affirmed the judgment. View "McNaughton v. State" on Justia Law

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Defendant appealed his conviction for felony murder, aggravated assault, and possession of a knife during the commission of a crime. The court rejected defendant's claims that trial counsel rendered ineffective assistance of counsel by introducing into evidence his videotaped statement to police without first redacting where he invoked his right to counsel and him asking God to have mercy on his soul; that the trial court erred by truncating his testimony that he was actually afraid of the victim and only acted in self-defense; that the trial court erred by not reading aloud to the jurors two stipulations agreed upon by the parties; that the trial court erred by failing to suppress his statement to an arresting officer that he had consumed seven alcoholic beverages on the night of the murder; and that the trial court erred by not instructing the jury regarding Miranda and the voluntariness of statements. Accordingly, the court affirmed the judgment. View "Martin v. State" on Justia Law

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Defendant was convicted of felony murder and acquitted of malice murder in connection with the shooting death of the victim. On appeal, defendant contended that the evidence at trial was insufficient to support the jury's verdict. The court affirmed the judgment and held that the evidence was sufficient to enable a rational trier of fact to find defendant guilty of felony murder beyond a reasonable doubt. View "Manzano v. State" on Justia Law

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Defendant appealed his conviction for felony murder, aggravated assault, and possession of a firearm during the commission of a felony, contending, among other things, that the trial court incorrectly charged the jury and that he received ineffective assistance of counsel. The court rejected defendant's claim of error regarding the jury charge where trial courts did not have to follow an exact formula in instructing juries so long as the charge as a whole ensured that the jury would consider whether the evidence of provocation and passion might authorize a verdict of voluntary manslaughter. The court also rejected defendant's claims of ineffective assistance of counsel where defendant himself placed the evidence at issue before the jury and where trial counsel did not render ineffective assistance by failing to object to a proper argument. Accordingly, the judgment was affirmed. View "Kendrick v. State" on Justia Law

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Defendant appealed his conviction for malice murder, aggravated assault, and possession of a firearm during the commission of a crime, contending that a co-defendant's statement was introduced into evidence in violation of Crawford v. Washington. The State correctly conceded that the co-defendant's statement to police during the investigation of the victim's murder was testimonial in nature and that it was improperly admitted because defendant could not confront the co-defendant, who died before the trial commenced. Under the facts of the case, however, this Crawford violation was harmless where the co-defendant's statement was cumulative of other properly admitted evidence. Accordingly, the judgment was affirmed. View "Jackson v. State" on Justia Law

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Defendant was convicted of felony murder and other related offenses in connection with the shooting death of the victim. On appeal, defendant claimed that the trial court erred in denying his Batson challenge to the State's peremptory strikes during jury selection and violated his Fourteenth Amendment Equal Protection rights relating to jury selection. The court held that a trial court's finding as to whether the opponent of a strike has proven discriminatory intent was entitled to great deference and would not be disturbed unless clearly erroneous. Applying this standard, defendant's contention that the State failed to give an adequate nondiscriminatory reason for striking Juror 24 was unpersuasive. Accordingly, the judgment was affirmed. View "Jackson v. State" on Justia Law

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Wife and husband were married in 1997 and wife filed a petition for divorce in 2010. At issue was whether the marital residence was subject to equitable division. The trial court found that the marital residence was wife's separate property and awarded her sole possession. Husband applied for discretionary appeal and the court granted the application pursuant to the Court's Rule 34(4). The court, however, rejected husband's contention that the trial court committed reversible error when it failed to enter a consolidated pretrial order in violation of OCGA 9-11-16 and a scheduling order. Accordingly, the court affirmed the judgment. View "Graham v. Graham" on Justia Law

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The court granted wife's application for interlocutory appeal to determine whether the trial court erred by denying her motion to dismiss for lack of personal jurisdiction. Finding that the wife did not have sufficient "minimum contacts" within the State of Georgia, the court held that the trial court did not have personal jurisdiction over the wife. The trial court did, however, have jurisdiction over the res of the marriage under OCGA 19-5-2. Accordingly, the court affirmed in part and reversed in part. View "Ennis v. Ennis" on Justia Law