Justia Georgia Supreme Court Opinion Summaries

Andrew Thomas Huber was convicted of felony murder predicated on aggravated assault in relation to the shooting death of Daniel Raburn. Huber, along with his accomplices Thomas Wayne Harper and Brandilee Nicole Woodard-Brady, were indicted on charges of malice murder, felony murder predicated on aggravated assault, and three counts of aggravated assault against Raburn. Prior to Huber's trial, Harper was convicted of voluntary manslaughter and aggravated assault, and Woodard-Brady pleaded guilty to voluntary manslaughter. A jury found Huber not guilty of malice murder but guilty of all the remaining counts against him. The trial court sentenced Huber to life in prison without the possibility of parole for felony murder. Huber filed a motion for a new trial, which was denied by the trial court.Huber appealed his conviction to the Supreme Court of Georgia, arguing that the evidence was insufficient to support his felony murder conviction, his trial counsel rendered ineffective assistance, and the trial court committed plain error in instructing the jury on simple assault and voluntary manslaughter. The Supreme Court of Georgia affirmed the lower court's decision. The court found that the evidence, when viewed in the light most favorable to the jury’s verdict, was sufficient to support Huber’s conviction for felony murder predicated on aggravated assault. The court also found that Huber's trial counsel did not render ineffective assistance and that the trial court did not commit plain error in its instructions to the jury. View "HUBER v. STATE" on Justia Law

The case involves Charles Michael Sconyers who was convicted for malice murder and cruelty to children in the first degree, in relation to the death of 23-month-old Lincoln Davitte. The child died from blunt-force trauma to his skull. Evidence presented at trial showed that Sconyers and the child's mother, Chelsea Finch, lived together and that the child sustained a severe head injury while under Sconyers' sole care. Sconyers claimed the injury was due to a ground-level fall on the patio, but several medical experts testified that the injury was inconsistent with such a fall.Sconyers was indicted for malice murder, two counts of felony murder, and one count each of aggravated assault and cruelty to children in the first degree. He was found guilty on all counts and sentenced to life in prison for malice murder and concurrent 20-year prison terms for aggravated assault and cruelty to children. The felony murder counts were vacated by operation of law. Sconyers filed a motion for a new trial, which was denied by the trial court. He then appealed to the Supreme Court of Georgia.Sconyers raised four issues on appeal: the trial court's repeated allowance of evidence of previous injuries to the child without cautioning the jury that the parties agreed Sconyers did not cause those injuries; the jury instruction about “prior difficulties” between Sconyers and the child without limiting what evidence qualified as prior difficulties; the admission of hearsay statements allegedly made by Finch; and the prosecution's alleged improper impeachment of Finch. The Supreme Court of Georgia affirmed the trial court's decision, rejecting all of Sconyers' arguments. View "Sconyers v. State" on Justia Law

Kiervon Armani Hooks was convicted of felony murder and possession of a firearm during the commission of a felony, both charges stemming from the shooting death of Brandon Ray Foster. The incident occurred on September 26, 2017, and Hooks was indicted on December 18, 2017. The jury found Hooks guilty of all counts during a trial held from February 4-6, 2019. He was sentenced to life without parole for felony murder and an additional five years for possession of a firearm during the commission of a felony. Hooks filed a motion for a new trial, which was denied by the trial court.Hooks appealed his conviction, arguing that the evidence was insufficient to sustain his convictions as no physical evidence or eyewitness testimony linked him to the crime scene. He also argued that the State did not present enough evidence to exclude the possibility that someone else shot Foster. However, the Supreme Court of Georgia affirmed his convictions.The court found that the evidence was constitutionally sufficient to uphold the convictions. The evidence included Foster's statement that "Buddha" shot him, with multiple witnesses identifying Hooks as the only person they knew by that nickname. Additionally, a .40-caliber shell casing was found near the building where Hooks was staying, and Hooks admitted to being in the building except for when he stepped out to smoke a cigarette. The court concluded that this evidence, viewed in the light most favorable to the verdicts, authorized the jury to find Hooks guilty of the felony murder of Foster and possession of a firearm during the commission of that crime. View "Hooks v. State" on Justia Law

Bryan Keith Schmitt was convicted of malice murder for the death of Hamid Jahangard, who died after being hit by Schmitt’s car. Schmitt was indicted on charges of malice murder, two counts of felony murder, and two counts of aggravated assault. The jury found Schmitt guilty on all counts, and he was sentenced to life in prison with the possibility of parole. Schmitt appealed, arguing that the trial court erred by denying his request to instruct the jury on the defense of accident.The Supreme Court of Georgia found that the trial court did err in denying Schmitt's request for an accident defense instruction. The court noted that there was at least slight evidence supporting Schmitt's claim that the collision was an accident, including his own testimony and expert testimony that he veered away from Jahangard before the collision. The court also noted that the trial court's instruction to the jury to disregard accident as a key legal principle was problematic, as it may have led the jury to disregard Schmitt's accident defense.The court concluded that the trial court's error was not harmless, as the evidence of Schmitt's criminal intent was disputed and not overwhelming. Therefore, the court reversed Schmitt's conviction. The court also found that the trial court erred in declining the accident instruction for the related counts of felony murder and aggravated assault, and reversed those verdicts as well. However, the court noted that the evidence was legally sufficient to sustain Schmitt’s conviction, and so the State may retry him. View "SCHMITT v. STATE" on Justia Law

Randy Leon Pittman, Jr. was convicted for malice murder and arson in connection with the shooting and burning death of Natoshia Smith. Pittman challenged his convictions on several grounds. He argued that the evidence was insufficient to identify Smith’s skeletal remains, that the trial court erred in denying his motion to disqualify the District Attorney who had previously represented him, that the trial court improperly prohibited him from asking witnesses about other fires that occurred while he was incarcerated, and that the trial court erred in denying a motion for mistrial.The case was previously reviewed by a Haralson County grand jury, which indicted Pittman for malice murder, felony murder, aggravated assault with a deadly weapon, arson in the first degree, and possession of a firearm by a convicted felon. The jury found Pittman guilty of the remaining charges and he was sentenced to life in prison without the possibility of parole for malice murder and a consecutive term of 20 years for arson. Pittman filed a motion for a new trial, which was denied by the trial court.The Supreme Court of Georgia affirmed the lower court's decision. The court found that the forensic evidence and eyewitness testimony were sufficient to identify Smith as the victim. The court also found no error in refusing to disqualify the District Attorney based on his prior representation of Pittman, as it was undisputed that the prior representation ended several years before and was completely unrelated to the murder prosecution. The court concluded that the trial court did not abuse its discretion in excluding evidence of other fires because the evidence was not relevant. Finally, the court concluded that Pittman did not preserve for appeal his claim related to the denial of his motion for mistrial. View "Pittman v. State" on Justia Law

Frederick Sauder was convicted of malice murder and other crimes related to the armed robbery of Wayne Alexander and his subsequent shooting death. The crimes occurred in August 2016, and Sauder was indicted in December 2017. The jury found Sauder guilty of the charges in February 2019, and he was sentenced to life in prison for malice murder, along with additional years for armed robbery, burglary, and possession of a firearm during the commission of a felony. Sauder appealed, arguing that the evidence presented at his trial was insufficient to support several of his convictions and that the trial court made several errors.The Supreme Court of Georgia found that the evidence presented at Sauder's trial was sufficient to support his convictions. The court also found that the trial court did not abuse its discretion by admitting into evidence an excerpt of a phone call Sauder made while in jail awaiting trial. The court did, however, vacate Sauder's conviction for possession of a firearm during the commission of aggravated assault due to a merger error, but affirmed his other convictions. View "SAUDER v. STATE" on Justia Law

Austin Stryker was convicted for malice murder and other crimes related to the shooting and stabbing death of Hannah Bender. Stryker was a member of a small gang, and the prosecution argued that he killed Bender because he suspected she was informing on the gang's activities. Stryker was charged with multiple counts, including malice murder, felony murder, aggravated assault, aggravated battery, possession of a firearm and knife during the commission of a felony, violating the Street Gang Terrorism and Prevention Act, concealing the death of another, and tampering with evidence. The jury found him guilty on all counts, and he was sentenced to life in prison without the possibility of parole for malice murder, along with consecutive sentences for other charges.Stryker appealed his convictions, arguing that the trial court violated his constitutional right to present a complete defense when it prevented his counsel from making a closing argument that co-defendants Issac Huff and Dylan Reid would have faced minimum sentences of life in prison had they not pled guilty. He also contended that the prosecutor personally attacked his defense counsel in closing argument and that the trial court erred in failing to charge the jury on “grave suspicion” after the prosecutor allegedly misconstrued the beyond-a-reasonable-doubt standard in closing arguments.The Supreme Court of Georgia affirmed Stryker's convictions, concluding that his claims failed. However, the court identified merger errors in Stryker’s sentencing that required correction, and thus vacated part of the judgment. View "STRYKER v. THE STATE" on Justia Law

Diante Thompson was convicted for malice murder and other crimes related to the stabbing death of Bobby Jermaine Ricks. Thompson, along with Demarco Draughn, Benny Hayward, and Xavier Levatte, were charged with malice murder, felony murder, and aggravated assault. Thompson's trial was severed from his co-indictees, who were also convicted of malice murder. The jury found Thompson guilty on all charges and he was sentenced to life in prison without the possibility of parole for malice murder. The felony-murder count was vacated by operation of law. Thompson filed a motion for a new trial, which was denied by the trial court.Thompson appealed his convictions, arguing that the evidence presented at trial was constitutionally insufficient to sustain his convictions and that the trial court erred by failing to grant a new trial. He also argued that the State committed reversible error in its closing argument by telling the jury that it needed to adjudicate the guilt of Thompson’s co-indictees, who were tried separately, and by allegedly shifting the burden of proof to Thompson. Additionally, Thompson argued that his trial counsel was constitutionally ineffective for failing to object to the same allegedly improper statements made by the State.The Supreme Court of Georgia affirmed Thompson’s convictions. The court found that the evidence at trial was sufficient to uphold Thompson’s convictions. The court also found that Thompson's claims of reversible error in the State's closing argument were not preserved for appellate review because defense counsel failed to object to the prosecutor’s allegedly improper statements at trial. Lastly, the court found that Thompson failed to show that his trial counsel was deficient for failing to object to the prosecutor’s allegedly burden-shifting comments. View "THOMPSON v. THE STATE" on Justia Law

The case revolves around Gavin Henderson, who was convicted by a DeKalb County jury for malice murder, cruelty to children in the first degree, and possession of a knife during the commission of a felony. The charges were related to the fatal stabbing of his sister, Kiara Henderson. Henderson was indicted for these charges on September 11, 2018, and found guilty on all counts on July 9, 2021. He was sentenced to life in prison without the possibility of parole for malice murder, among other sentences for the remaining charges. Henderson filed a motion for a new trial, which was denied by the trial court.The case was then brought to the Supreme Court of Georgia. Henderson argued that the trial court erred in admitting prior-acts evidence, failed to charge the jury on the law of voluntary manslaughter, and committed cumulative errors that require reversal. The Supreme Court of Georgia, however, found Henderson's claims of error to be without merit. The court affirmed the trial court's order denying Henderson's motion for a new trial. The court found that the evidence of Henderson's prior violent acts was admissible for purposes of proving his intent, and that there was no evidence to support giving an instruction on voluntary manslaughter. The court also found that Henderson failed to demonstrate any trial court error that would warrant a new trial. View "HENDERSON v. THE STATE" on Justia Law

Richard Stroud Jr. was convicted of felony murder and possession of a firearm during the commission of a felony in relation to the shooting death of Frederick Cade. Stroud and Jarvis Lamont Milton were indicted on multiple charges, including violating the Street Gang Terrorism and Prevention Act, malice murder, felony murder based on aggravated assault, possession of a firearm in the commission of a crime, and aggravated assault. After Milton's case was severed, Stroud was tried before a jury and was acquitted on the malice murder charge but found guilty on the remaining charges. Stroud was sentenced to life in prison with the possibility of parole for the felony murder charge and five years in prison for the firearm possession charge, to run consecutively.Stroud filed a motion for a new trial, which was denied by the trial court. He then appealed his convictions, arguing that the State did not present sufficient evidence to support his convictions beyond a reasonable doubt and that the trial court should have granted his motion for a directed verdict.The Supreme Court of Georgia affirmed Stroud's convictions. The court found that the evidence presented at trial, when viewed in the light most favorable to the jury's verdict, was sufficient to support Stroud's convictions for felony murder predicated on aggravated assault and possession of a firearm during the commission of a felony. The court concluded that even if the jury believed that Milton, and not Stroud, shot Cade, there was ample evidence of Stroud's conduct before, during, and after the shooting for the jury to find Stroud guilty as a party to the crimes because of a shared criminal intent. The court also found that the trial court did not err in denying Stroud's motion for a directed verdict. View "STROUD v. THE STATE" on Justia Law