Justia Georgia Supreme Court Opinion Summaries

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

DeRon Edrias Gude was convicted of felony murder and other charges related to the shooting death of Nyyokokie Hendley. On October 11, 2016, Gude called 911 to report a shooting at his home, claiming it was an accident during a fight. Police found Hendley dead from a gunshot wound to the head, with a 9-millimeter handgun near her feet and marijuana in an unlocked safe. Gude was indicted on multiple charges, including malice murder and felony murder. At trial, Gude testified that Hendley had threatened him and pointed a gun at him, leading him to shoot her in self-defense. The jury found Gude guilty of felony murder predicated on aggravated assault and other charges.The DeKalb County Superior Court granted Gude’s motion for a directed verdict of acquittal on the marijuana charge, and the jury found him not guilty of malice murder but guilty on the remaining counts. Gude was sentenced to life in prison for felony murder predicated on aggravated assault, plus five years for possession of a firearm during the commission of a felony. Gude’s motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case and addressed Gude’s claims of plain error in the jury charge on aggravated assault and ineffective assistance of counsel. The court assumed, without deciding, that the trial court committed an obvious error in the jury instruction but found that Gude failed to show the error likely affected the trial's outcome. The court noted that the jury was properly instructed on the burden of proof and provided with a copy of the indictment. Additionally, Gude’s defense was self-defense, and the jury’s verdict indicated they found he intended to shoot Hendley. Consequently, the court affirmed the trial court’s judgment, concluding that Gude did not demonstrate plain error or ineffective assistance of counsel. View "GUDE v. THE STATE" on Justia Law

An attorney, Brian Steel, was found in contempt of court for refusing to disclose how he learned about an ex parte hearing involving a witness, the witness's counsel, and prosecutors in a case where Steel represented a defendant. The trial judge, Judge Glanville, repeatedly asked Steel to reveal his source, but Steel claimed the information was protected by attorney-client privilege and attorney work product. Judge Glanville held Steel in contempt and ordered him into custody, although Steel was later allowed to return to the courtroom.The Fulton County Superior Court initially found Steel in contempt and ordered him to be taken into custody. Steel argued that the information was privileged and that due process required Judge Glanville to recuse himself from the contempt proceedings. Despite these arguments, Judge Glanville sentenced Steel to 20 days in jail to be served on weekends and denied him a supersedeas bond.The Supreme Court of Georgia reviewed the case and determined that due process required Judge Glanville to recuse himself from the contempt proceedings. The court held that because the punishment was delayed and the alleged disobedience was directed toward the judge, a different judge should have presided over the contempt hearing. The court reversed the judgment of contempt imposed by the trial court. View "STEEL v. THE STATE" on Justia Law

The plaintiffs, who operate restaurants under franchise agreements, filed a Chapter 11 bankruptcy petition based on advice from their legal counsel. This led to the franchisor terminating the franchise agreements. The plaintiffs then sued their lawyers and law firms for legal malpractice and breach of written contracts for legal services, alleging that the lawyers' advice constituted malpractice. The defendants moved to dismiss both claims, arguing they were barred by a four-year statute of limitation under OCGA § 9-3-25.The trial court dismissed the legal-malpractice claims but denied the motion to dismiss the breach-of-contract claims. Later, it granted summary judgment for a subset of defendants, ruling that the breach-of-contract claims were also barred by the four-year statute of limitation. The Court of Appeals affirmed the dismissal of the legal-malpractice claims and concluded that the breach-of-contract claims were duplicative and should be dismissed as well.The Supreme Court of Georgia reviewed the case to determine which statute of limitation applies to breach-of-contract-for-legal-services claims and whether the Court of Appeals erred in dismissing these claims as duplicative. The Supreme Court concluded that such claims could be governed by either a six-year statute of limitation under OCGA § 9-3-24 or a four-year statute under OCGA § 9-3-25, depending on whether the breach arose directly from a written contract. The Court also held that the Court of Appeals erred in dismissing the breach-of-contract claims as duplicative without applying the proper motion-to-dismiss standard.The Supreme Court vacated the Court of Appeals' judgment and remanded the case for further proceedings consistent with its opinion, emphasizing that plaintiffs can pursue alternative theories of relief based on the same conduct. View "TITSHAW v. GEER" on Justia Law

Andy Espinosa pleaded guilty to the malice murder of Zachary Mejia and other related offenses. Espinosa was living with his girlfriend and her four children, including Zachary. On December 8, 2020, Espinosa and Zachary had a physical altercation, which left Espinosa feeling humiliated. The next day, Espinosa searched online about what it feels like to murder someone. Later that day, he returned home, grabbed a knife, and fatally stabbed Zachary. Espinosa called 9-1-1 and was arrested. He later claimed he was overtaken by a "demon" during the stabbing.Espinosa was indicted by a Chattooga County grand jury and pleaded guilty to all counts without a sentencing recommendation from the State. The trial court sentenced him to life without parole for malice murder, a consecutive five-year term for possession of a knife during the commission of a felony, and a concurrent 12-month term for cruelty to children in the third degree. Espinosa filed a motion to withdraw his guilty plea, arguing ineffective assistance of counsel for not advising him of an insanity defense.The Supreme Court of Georgia reviewed the case. Espinosa claimed his plea counsel was ineffective for not investigating his mental state and advising him of a potential insanity defense. Plea counsel testified that he did not see a viable defense and believed a plea was in Espinosa's best interest. The court found that counsel's performance was not deficient, as his strategic decisions were based on his professional judgment and experience. The court also noted that Espinosa did not provide evidence of past mental health issues or expert testimony supporting an insanity defense.The Supreme Court of Georgia affirmed the trial court's decision, concluding that there was no abuse of discretion in denying Espinosa's motion to withdraw his guilty plea. The court held that Espinosa failed to demonstrate that his counsel's performance was constitutionally deficient. View "Espinosa v. State" on Justia Law

Michael Earl Summerville was convicted of felony murder in connection with the death of Martha West. On December 10, 2017, Summerville and West, who were romantic partners, visited their neighbor Johnny Clark. After an argument, Summerville returned to Clark’s home later that night, reporting that West had fallen in a nearby field. West was found deceased in the field, with evidence suggesting she had been struck by a vehicle. Summerville’s truck showed signs of a collision, and fibers consistent with West’s clothing were found on the truck. An autopsy revealed extensive injuries consistent with being struck by a motor vehicle.A Wilkes County grand jury indicted Summerville for malice murder, felony murder predicated on aggravated assault, and aggravated assault, family violence. He was found not guilty of malice murder but guilty of the remaining charges. The trial court sentenced him to life in prison for felony murder, with the aggravated assault charge merging for sentencing purposes. Summerville’s motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Summerville’s claims of ineffective assistance of counsel and trial court error. Summerville argued that his trial counsel was ineffective for not objecting to a comment in the State’s closing argument and that the trial court improperly limited cross-examination of a witness. The court held that the prosecutor’s comment during closing arguments was a permissible inference from the evidence, and thus, any objection would have been meritless. Additionally, the court found no abuse of discretion in limiting the cross-examination of the medical examiner, as Summerville failed to show that the examiner’s prior disciplinary action was probative of potential bias. The court affirmed the trial court’s judgment. View "Summerville v. State" on Justia Law

In March 2020, the appellant was convicted of malice murder and related charges for the shooting death of Mondavius Milan. The incident occurred on April 3, 2018, in Atlanta, involving a check fraud scheme with the appellant, Milan, and Jaleesia Mathis. On the morning of the shooting, the group, including Mathis's partner Japhar White, was in a car when an argument over missing money escalated. Witnesses testified that the appellant pulled out a gun, and after a struggle, Milan was shot. Both Mathis and White fled the scene, later identifying the appellant as the shooter. The appellant was arrested in Massachusetts and extradited to Georgia.The appellant was indicted by a Fulton County grand jury and found guilty on all counts by a jury. The trial court sentenced him to life in prison for malice murder and additional consecutive sentences for firearm charges. The appellant's motion for a new trial was denied by the trial court after an evidentiary hearing. The appellant then filed a timely notice of appeal.The Supreme Court of Georgia reviewed the case, focusing on two main contentions: ineffective assistance of counsel and insufficient evidence. The court held that the appellant's trial counsel was not ineffective for advising him not to testify, as the counsel's advice was based on reasonable strategic considerations. The court also found that the evidence, including corroborating testimony from accomplices and other witnesses, was sufficient to support the conviction. The court affirmed the trial court's judgment, concluding that the appellant's claims lacked merit. View "NABORS v. THE STATE" on Justia Law