Justia Georgia Supreme Court Opinion Summaries

Defendant and co-defendant were convicted of felony murder, aggravated assault, and two counts of possession of a firearm during the commission of a felony. Defendant was separately convicted of theft by receiving a Toyota Highlander. Defendant appealed his conviction, asserting ineffective assistance of counsel. The court held that counsel was not ineffective in failing to exclude an out-of-court identification of defendant; trial counsel was not ineffective in failing to call two witnesses to testify for defendant at trial; counsel was not ineffective in failing to object to the State's oral requests to charge the jury on testimony of a single witness and parties to a crime; and trial counsel was not ineffective in failing to object to and move to exclude the testimony regarding a State's witness's threatening conduct. Accordingly, the judgment was affirmed. View "Williams v. State" on Justia Law

Defendant and co-defendant were convicted of felony murder, aggravated assault, and two counts of possession of a firearm during the commission of a felony. Defendant appealed his conviction. The court held that "merely listing the possible guilty verdict option(s) before the 'Not Guilty' option" on a pre-printed verdict form would not by itself mislead the jury as to the presumption of innocence; the trial court did not abuse its discretion in permitting the lead detective to remain in the courtroom during the three-day trial; and defendant failed to carry his burden of demonstrating ineffective assistance of counsel. Accordingly, the judgment was affirmed. View "Mitchell v. State" on Justia Law

Defendant was convicted of malice murder, felony murder, and cruelty to children arising out of the death of a 15-month-old. Defendant appealed the denial of his motion for a new trial alleging that the trial court committed plain error by making a number of improper statements during the course of the trial and by failing to sever his trial from that of his co-defendant. Because the trial court's favorable comments regarding one of the State's witnesses, a detective, could have been construed by the jury as bolstering that witnesses' testimony, the court reversed and remanded for a new trial View "Murphy v. State" on Justia Law

Defendant was convicted of the malice murder of his fiancee and was sentenced to life imprisonment. Defendant appealed the denial of his motion for a new trial. The court concluded that the evidence was sufficient to enable a rational jury to find beyond a reasonable doubt that defendant was guilty of murder; the trial court did not abuse its discretion in admitting evidence of allegedly similar transactions involving his ex-wife and occurring a decade or more before the victim's death; the charge on OCGA 16-3-21(b)(3) "was at most merely irrelevant, being one of a number of stated exceptions to the rule concerning the use of force in self-defense" and the trial court not only instructed the jury on self-defenses as set forth in subsection (a), it also fully charged on the doctrine of reasonable fears, on the absence of a duty to retreat, and on the State's burden of proving beyond a reasonable doubt that defendant was not justified; and the prior admission of a similar transaction from which the jury could draw certain limited inferences did not make unreasonable defense counsel's strategy to avoid offering testimony of defendant's nonviolent character. Accordingly, the judgment was affirmed. View "Neal v. State" on Justia Law

SES is a company that makes and supplies outer components or "skins" for grocery store refrigeration units. SES was formed in 2009 when its immediate predecessor, SER, was foreclosed by its bank. SES subsequently sued appellants, employees of SER, for injunctive relief under the Georgia Trade Secrets Act (GTSA), OCGA 10-1-760 et seq. Appellants then appealed, contending that the trial court erred when it found SES had standing to sue and when it granted equitable relief after finding that the preemption clause of the GTSA was inapplicable. The court held that, based upon the unique facts of the case, the trial court did not err when it declined to deny SES's action for lack of standing. The court found, however, that the trial court manifestly abused its discretion when it granted equitable relief to SES because the trial court's reliance on Owens v. Ink Wizard Tattoos was erroneous and the GTSA superseded all conflicting laws providing restitution or civil remedies for the misappropriation of trade secrets. Accordingly, the trial court's award of equitable relief pursuant to OCGA 9-5-1 was a manifest abuse of discretion and must be reversed. View "Robins, et al. v. Supermarket Equipment Sales, LLC; Smith v. Supermarket Equipment Sales" on Justia Law

In June 2002, Holders purchased from Brenda Ruth Pruitt Griffin a 70-acre tract of land in Gwinnett County. As part of the consideration for the purchase, Griffin was to grant Holders a right of first refusal to acquire an approximately 74-acre tract located across the road. Holders subsequently appealed from an order of the superior court ruling adversely on their claims for compensation stemming from Gwinnett County's condemnation of a portion of the real property subject to the right of first refusal. The court found that the right of first refusal in this case was not compensable under the 1983 Georgia Constitution, Art. I, Sec. III, Par. I, and affirmed the judgment of the superior court. View "Robinson, et al. v. Gwinnett County, et al." on Justia Law

Defendant was convicted of child molestation based on an incident that occurred in a restroom at Screven County High School. During trial, the State failed to introduce any direct evidence that the crime occurred in Screven County. Defendant appealed his conviction and the Court of Appeals reversed, holding that, pursuant to Thompson v. Brown, in the absence of evidence that Screven County High School was located in Screven County, evidence of venue was lacking. Because the court found the evidence, albeit circumstantial, sufficient to prove venue beyond a reasonable doubt, the court reversed the judgment. View "State v. Prescott" on Justia Law

Defendant appealed his convictions for malice murder, felony murder, aggravated assault, possession of a knife during the commission of a crime, and cruelty to children in the third degree, contending that the trial court erred in admitting certain incriminating statements made by him to the State's psychiatric expert. The court held that because defendant chose to call an expert to testify regarding his mental state at the time of the crime, the State had a statutory right to call its expert in rebuttal. Accordingly, the judgment was affirmed. View "Walker v. State" on Justia Law

Defendant was convicted of voluntary manslaughter and sentenced to 20 years in prison. The habeas court subsequently found that defendant's appellate counsel had been deficient for failing to ensure the transcript of the hearing on the motion to dismiss the jury panel was included in the record on appeal and that defendant was prejudiced by this deficiency. After review, the court found that the habeas court's findings of facts were supported by the record and thus were not clearly erroneous. However, the habeas court erred by simply presuming prejudice from the alleged deficiency. The burden was on defendant to show prejudice and the habeas court failed to explain how this burden was met. Accordingly, the habeas court erred in granting the petition for writ of habeas corpus and the judgment was reversed.

Joseph Washington and his wife field a quiet title action to establish that they had legal title to some disputed land. Joan Brown, Washington's sister, counterclaimed with her own quiet title action, seeking to establish that she was the rightful owner of the disputed land. The Special Master concluded that Brown was the rightful owner, the trial court entered an order that incorporated the Special Master's report and ruled in favor of Brown, and the Washingtons subsequently appealed. Because there was no evidence to support the conclusion that Brown owned the disputed property either by deed or by adverse possession, the court reversed that portion of the trial court's order awarding the disputed property to Brown. However, because evidence did not support the trial court's conclusion that the Washingtons also did not own the disputed property, that portion of the order determining that the Washingtons do not own the property must be upheld on appeal. Accordingly, the court affirmed in part and reversed in part.