Justia Georgia Supreme Court Opinion Summaries

Deangelo Deshawn Morgan was convicted in 2023 for the fatal shooting of Sabron Mosby and the aggravated assault of Donoven King. The crimes occurred on October 15, 2018, and Morgan was indicted along with Cleavanta Jerrideau and Glenn Darius Smith. Morgan's trial was severed due to a conflict of interest with his counsel, and Jerrideau and Smith were acquitted in their joint trial. Morgan was later found guilty by a jury and sentenced to life in prison with the possibility of parole for malice murder and an additional twenty years for aggravated assault.Morgan's motion for a new trial was denied by the trial court after an evidentiary hearing. He appealed, arguing that the trial court abused its discretion by excluding evidence that the shooting was drug-related and implicating other potential suspects. He also claimed his trial counsel was ineffective for not properly arguing for the admission of this evidence and advising him not to testify.The Supreme Court of Georgia reviewed the case and found that the trial court did not abuse its discretion in excluding the evidence. The court held that the excluded evidence did not raise a reasonable inference of Morgan's innocence and was speculative. Additionally, the court found that Morgan's trial counsel's performance was not deficient, as the advice given was a strategic decision and not patently unreasonable.The Supreme Court of Georgia affirmed the trial court's decision, upholding Morgan's convictions and sentences. View "MORGAN v. THE STATE" on Justia Law

Alfred Jermaine Arnold was convicted of malice murder and other crimes related to the death of Loretta Goolsby, who was beaten to death between April 5 and 6, 2019. Arnold was indicted on multiple counts, including malice murder, felony murder, aggravated assault, arson, and theft by taking. The jury found him guilty on all counts, and he was sentenced to life without parole for malice murder, plus additional concurrent sentences for arson and theft. Arnold's motion for a new trial was denied, leading to his appeal.Arnold argued that the evidence was insufficient to support the verdicts, his discovery rights were violated, his trial counsel was ineffective, and the trial court erred in admitting expert testimony. The Supreme Court of Georgia reviewed the case. The court found that the evidence, including cell phone location data, fingerprint evidence, and Arnold's inconsistent statements, was sufficient to support the convictions. The court also determined that there were no discovery violations, as Arnold had been provided with the expert's reports and was aware of the expert's conclusions.Regarding the ineffective assistance of counsel claim, the court concluded that Arnold's trial counsel's performance was not deficient, as they employed a reasonable strategy in handling the fingerprint evidence and cross-examining the expert. Additionally, Arnold failed to demonstrate that he was prejudiced by his counsel's performance, as he did not provide evidence that he would have accepted a plea offer or that an independent expert would have provided different testimony.The court also upheld the trial court's decision to admit the expert testimony under the Daubert standard and OCGA § 24-7-702 (b), finding that the expert was qualified and her methods were reliable. Consequently, the Supreme Court of Georgia affirmed Arnold's convictions. View "ARNOLD v. THE STATE" on Justia Law

Ashton Denny, Jr. was convicted of malice murder and other charges after shooting his half-brother, Kevin Rowe, in the back, resulting in Rowe's death. The incident occurred on May 28, 2020, following an argument between Denny and Rowe at their family home in Conyers, Georgia. After the argument, Rowe and other family members left but returned later that night. Rowe stepped outside, followed by Denny, and shortly after, a gunshot was heard. Rowe was found injured, claiming Denny shot him, and Denny fled the scene in his Jeep. Denny was later apprehended when he returned to the scene.A Rockdale County grand jury indicted Denny on charges including malice murder and possession of a firearm during the commission of a crime. The jury found Denny guilty on all counts, and he was sentenced to life in prison without parole for malice murder, with additional consecutive sentences for other charges. Denny's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case, where Denny argued ineffective assistance of counsel. He claimed his trial counsel failed to object to the admission of the murder weapon and other evidence from his Jeep, failed to object to the admission of a door with a bullet hole, and failed to tender a gunshot residue report. The court found that Denny's counsel was not deficient, as objections to the evidence would have been fruitless and the strategic decisions made by counsel were reasonable. The court also determined that Denny did not demonstrate a reasonable probability that the trial outcome would have been different had the gunshot residue report been admitted. Consequently, the Supreme Court of Georgia affirmed the trial court's judgment. View "DENNY v. THE STATE" on Justia Law

Lucianna Nicole Fox was convicted of felony murder and other crimes related to the shooting death of Leroy Midyette. On November 5, 2016, Fox encountered Midyette at a MARTA station. After a confrontation where Midyette did not move his cart out of the way, Fox hit the cart with her vehicle. Midyette followed her car and hit it, prompting Fox to exit her vehicle and shoot him, claiming she felt threatened. Fox was arrested and, during a police interview, stated she shot Midyette because she feared he had a weapon.Fox was indicted by a Fulton County grand jury and found guilty of felony murder, aggravated assault, and possession of a firearm during the commission of a felony. She was sentenced to life with the possibility of parole for felony murder and an additional five years for the firearm charge. Her motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case. Fox argued that her trial counsel was ineffective for not requesting a jury charge on the defense of accident and that the trial court committed plain error in its jury instructions. The court found that her counsel’s decision to focus solely on self-defense was not unreasonable and did not constitute ineffective assistance. The court also determined that any error in the jury instructions did not likely affect the trial's outcome. Consequently, the court affirmed Fox’s convictions, finding no cumulative error that denied her a fair trial. View "FOX v. THE STATE" on Justia Law

Michael Williams was convicted of malice murder and other offenses for the fatal shooting of Tomas Gooden at a house party on December 8, 2017. Williams and Gooden argued over a gambling game, leading to Gooden pushing Williams to the floor. Williams then shot Gooden in the head and fled the scene. Gooden's body was found in the garage, and the medical examiner determined the bullet traveled in a downward trajectory. Williams was later found walking along the road and eventually admitted to shooting Gooden, claiming self-defense.A Coweta County grand jury indicted Williams on multiple charges, including malice murder and aggravated assault. Williams was found guilty on all counts by a jury and sentenced to life in prison for malice murder, with additional concurrent and consecutive sentences for other charges. Williams filed a motion for a new trial, which was denied. He then appealed to the Supreme Court of Georgia, specifying that he was not appealing his conviction for possession of a firearm by a convicted felon.The Supreme Court of Georgia reviewed Williams's claims of plain error in the jury instructions and ineffective assistance of counsel. Williams argued that the trial court failed to instruct the jury that the State bore the burden to disprove his justification defense and that his counsel failed to investigate and introduce evidence of Gooden's violent reputation. The court concluded that although the trial court erred in its jury instructions, Williams did not demonstrate that this error affected the trial's outcome. Additionally, the court found that Williams was not prejudiced by his counsel's performance, as substantial evidence of Gooden's violent character was already presented at trial. Consequently, the Supreme Court of Georgia affirmed Williams's convictions. View "WILLIAMS v. THE STATE" on Justia Law

Henry Lamar Willis was admitted to the Bar in 2006 and established a law firm. In 2012, he failed to respond to a Formal Complaint by the State Bar regarding his improper handling and conversion of $30,000 in settlement funds. The special master entered a default judgment, and the Supreme Court of Georgia disbarred Willis in 2013 for violations of several Georgia Rules of Professional Conduct, including acting with reasonable diligence, keeping client funds separate, and not engaging in dishonest conduct.Willis sought readmission to the Bar, claiming a twelve-year rehabilitation process. The Board to Determine Fitness of Bar Applicants reviewed his application and recommended granting it. Willis provided a statement of rehabilitation, explaining personal and professional hardships, including a divorce and loss of a city council re-election bid. He detailed his efforts to rebuild his life, including paying all due funds, engaging in various personal development activities, and receiving support from several attorneys and a city council member.The Fitness Board conducted an investigation, including notifying the State Bar, the public, and the judiciary. The State Bar noted a pending grievance at the time of Willis's disbarment, which was declared moot. Willis paid $4,800 owed to the Clients' Security Fund. At an informal conference, Willis took responsibility for his past conduct and demonstrated his rehabilitation.The Supreme Court of Georgia reviewed the record and concluded that Willis had demonstrated rehabilitation by clear and convincing evidence. The Court granted Willis's Application for Certification of Fitness, allowing him to be readmitted to the Bar upon satisfying all requirements, including passing the Georgia Bar Examination. View "In re Willis" on Justia Law

Charvez Ryals was convicted of malice murder and other crimes related to the beating and fatal shooting of Daniel Wise. The incident occurred on March 10, 2018, in DeKalb County, Georgia. Ryals and his girlfriend, Regina Welch, had a history of domestic violence involving Wise, who was Regina's ex-boyfriend and the father of her three children. On the night before the murder, Wise confronted Regina and Ryals, demanding money and threatening them. The next morning, Wise returned to Regina's apartment, leading to a confrontation where Ryals shot Wise multiple times, resulting in his death.The case was initially tried in the Superior Court of DeKalb County, where a jury found Ryals guilty on all counts, including malice murder, felony murder, aggravated assault, cruelty to children, and firearm possession. The trial court sentenced Ryals to life in prison for malice murder, along with additional concurrent and consecutive sentences for the other charges. Ryals filed a motion for a new trial, which was denied by the trial court in March 2024.The Supreme Court of Georgia reviewed the case, focusing on Ryals' claims of ineffective assistance of counsel. Ryals argued that his trial counsel failed to subpoena a key witness, obtain phone records, introduce the criminal histories of Wise and another victim, and request a jury charge on voluntary manslaughter. The court found that these claims did not demonstrate deficient performance or resulting prejudice. The court held that the decisions made by Ryals' counsel were reasonable and strategic, and that any potential deficiencies did not affect the outcome of the trial. Consequently, the Supreme Court of Georgia affirmed the lower court's judgment, upholding Ryals' convictions and sentences. View "RYALS v. THE STATE" on Justia Law

Brendan Riley was charged and convicted of murder and other crimes related to the shooting death of Glentis Wheeler. The State appealed the trial court's decision to grant Riley's amended motion for a new trial on the grounds of ineffective assistance of counsel, except for one count. Riley argued that his trial counsel was ineffective for not challenging the charging document, which he claimed was ambiguous and could have led to the dismissal of most charges if a general demurrer had been filed.The trial court found that the charging document did not meet the statutory requirements for an indictment and instead met the requirements of an accusation. Since certain crimes Riley was charged with could not be brought by accusation, the trial court ruled that his trial counsel was deficient for not challenging the document, resulting in prejudice to Riley. Consequently, the trial court granted Riley a new trial for most counts but did not address other arguments in his motion for a new trial.The Supreme Court of Georgia reviewed the case and determined that the charging document, while ambiguous, contained indications that it could be considered an indictment. The court found no binding precedent that would have required the trial court to dismiss the charges if a general demurrer had been filed. Therefore, the court concluded that Riley's trial counsel did not perform deficiently by failing to challenge the document. The Supreme Court of Georgia reversed the trial court's decision to grant a new trial for most counts and remanded the case for consideration of the remaining arguments in Riley's amended motion for a new trial. View "THE STATE v. RILEY" on Justia Law

The appellant, Jamie Alexander Washington, was convicted of felony murder and related crimes connected to the aggravated assault of Desmond Carter and the shooting death of James Hawkins in Dougherty County. The crimes occurred on July 5, 2015. Washington, along with co-defendants Mylan Mahoney and Malcolm Bernard Offord, Jr., was indicted on October 1, 2015, and reindicted on February 8, 2017. Mahoney and Offord pled guilty and testified against Washington. Washington was tried before a jury in February 2020, found guilty, and sentenced to life in prison without parole for felony murder, with additional concurrent and consecutive sentences for other charges.Washington filed a motion for a new trial, which was denied by the trial court on March 11, 2024. He then appealed to the Supreme Court of Georgia, raising several claims of trial-court error and ineffective assistance of counsel.The Supreme Court of Georgia reviewed the case and found the evidence sufficient to support Washington's conviction for felony murder, rejecting his argument that the evidence was insufficient under Georgia’s accomplice-corroboration statute. The court also found no plain error in the trial court's questioning of a witness, which Washington claimed expressed an opinion on the evidence. Additionally, the court concluded that any error in allowing the State to cross-examine Washington about his criminal history was harmless given the strong evidence against him.Regarding ineffective assistance of counsel claims, the court determined that Washington's trial counsel was not deficient in failing to locate a witness, object to hearsay testimony, request an alibi instruction, or object to certain prosecutorial comments during closing arguments. The court also found no cumulative prejudice from the alleged errors and instances of ineffective assistance.The Supreme Court of Georgia affirmed Washington's convictions. View "WASHINGTON v. THE STATE" on Justia Law

Damone Blalock and Rodalius Eugene Ryan, Jr. were convicted of the malice murder of Jamari Holmes, aggravated assaults of two other individuals, and related crimes. The crimes occurred on February 23, 2019, and the appellants were indicted in May 2019. They were tried together before a jury from September 21 to October 1, 2021, and found guilty on all presented counts. The trial court sentenced them to life in prison for malice murder, with additional consecutive and concurrent sentences for other charges. Their motions for a new trial were denied, leading to this appeal.The appellants argued that their trial counsel provided ineffective assistance in several ways, including failing to object to a witness invoking the Fifth Amendment in front of the jury, not introducing certain evidence, and not objecting to the prosecutor's comments on their silence during closing arguments. Ryan also claimed his counsel failed to investigate his alibi. The trial court found that while counsel was deficient in not reviewing certain evidence, the appellants failed to show that this deficiency prejudiced the outcome of the trial.The Supreme Court of Georgia reviewed the case and affirmed the lower court's decision. The court held that the trial counsel's strategic decisions, including not objecting to the witness's invocation of the Fifth Amendment and not pursuing the alibi defense, were reasonable. The court also found that the appellants did not demonstrate that the outcome of the trial would have been different if the alleged deficiencies had not occurred. The cumulative effect of the assumed deficiencies did not warrant a new trial. Thus, the convictions and sentences were affirmed. View "BLALOCK v. THE STATE" on Justia Law