Justia Georgia Supreme Court Opinion Summaries

Appellee DeJuan Spratlin was convicted of malice murder and a firearm offense in connection with the shooting death of Edward Cobb. The trial court granted Spratlin a new trial on the ground that his trial counsel provided ineffective assistance by failing to seek the exclusion of testimony and comments about his post-arrest silence. The State appealed that ruling. The Georgia Supreme Court determined there was not a reasonable probability that, but for the limited deficient performance by Spratlin’s trial counsel, the jury at his trial would have reached a different result. The Court therefore reversed the trial court’s order granting Spratlin a new trial. View "Georgia v. Spratlin" on Justia Law

Appellant Brisean Esprit was convicted of felony murder; appellant Mark Jones was convicted of malice murder. Both were convicted of a firearm offense in connection with the shooting death of Maximillion Stevenson. Esprit’s sole contention on appeal was that his trial counsel provided ineffective assistance by failing to properly seek admission of statements favorable to Esprit that Jones made during Jones’s truncated attempt to enter a guilty plea just before trial. Jones’s sole contention was that the trial court erred by overruling his objection to similar transaction evidence. The Georgia Supreme Court concluded after review that both appellants’ contentions were meritless, so it affirmed the convictions in both cases. View "Esprit v. Georgia" on Justia Law

In one of first impression for the Georgia Supreme Court, the issue this case presented centered on the effect of the State’s delay in obtaining search warrants for data contained in electronic devices when those devices were originally seized in a warrantless, but lawful, manner by police. The trial court suppressed the evidence derived from the devices, relying on persuasive authority from the United States Court of Appeals for the Eleventh Circuit to find that the delay between the seizure of the devices and the issuance of the search warrants for the data contained in them was unreasonable and thus violated appellees’ rights under the Fourth Amendment and Georgia law. The State appealed that decision. The Georgia Supreme Court concluded the analysis developed by the Eleventh Circuit was appropriate, the trial court’s findings of fact were supported by the record, and the trial court did not err in granting the motion to suppress. View "Georgia v. Rosenbaum" on Justia Law

Michael Licata's vehicle was stopped by police because it matched the description of a vehicle that had recently been in an accident and had significant front-end damage. Prior to the stop, sparks were coming off the asphalt as Licata had been driving on the vehicle’s rims. The police officer who ultimately arrested Licata approached Licata and confirmed with Licata that Licata had been involved in an accident. The arresting officer told Licata that he wanted to discuss the accident but he wanted to read Miranda warnings to Licata first. After doing so, the arresting officer asked Licata several questions about the accident. A short time later, the officer asked Licata to perform field sobriety tests. Licata complied and failed the tests. The officer then placed Licata under arrest for DUI less safe, read the implied consent warning, and asked Licata if he would submit to a breath test. Licata twice asked to call his attorney but was denied that request. Licata ultimately responded that he would not submit to a breath test. Following his arrest and prior to trial, Licata sought to suppress the results of his field sobriety tests and evidence that he refused to submit to the breath test. The trial court granted Licata’s motion, concluding that the field sobriety evaluations should have been suppressed because Licata was in custody and was not informed that he had a right to refuse to perform incriminating acts, a right protected by Article I, Section I, Paragraph XVI of the Georgia Constitution of 1983. The Georgia Supreme Court granted certiorari to consider what, if any, Miranda-type warning law enforcement must give before asking a suspect in custody to perform acts protected by Paragraph XVI, and whether a suspect in custody is entitled to the advice of counsel when asked to submit to a state-administered breath test. After its review of the record, the Court determined Licata was not actually in custody. Therefore, it affirmed the Court of Appeals’s ultimate conclusion that the field sobriety tests were admissible, without answering the first question. The Court declined to resolve the issue regarding the advice of counsel, because it was pertinent only to the the admissibility of Licata’s refusal to submit to a breath test, and this determination must be reconsidered in the light of our recent opinion in Elliott v. Georgia (Case No. S18A1204, decided February 18, 2019), wherein the Court concluded refusal evidence was inadmissible. Therefore, the Court of Appeals’ opinion regarding the admissibility of the refusal evidence was vacated and the matter remanded for further proceedings. View "Licata v. Georgia" on Justia Law

Deondray Yarn was convicted of murder and other crimes in connection with the January 2014 shooting death of Monnie Brabham. On appeal, Yarn argued: (1) the evidence was insufficient to support his convictions; (2) the trial court abused its discretion in granting continuances over Yarn’s objections; and (3) his trial counsel was ineffective in communicating a plea offer to Yarn. Finding no error, the Georgia Supreme Court affirmed. View "Yarn v. Georgia" on Justia Law

In 2014, Maria Matta-Troncoso and her husband, Mario Matta (“the Mattas”), sued Michael and Lakeisha Thornton, alleging that the Thorntons were liable under OCGA 51-2-71 for injuries that Matta-Troncoso sustained when the Thorntons’ dogs attacked her as she was walking her own dogs approximately two blocks away from the Thorntons’ rental house. The Mattas later amended their complaint by adding Gregory Tyner, the Thorntons’ landlord, alleging that he was liable under OCGA 44-7-142 for failing to keep the rental property in repair. Specifically, they alleged that Tyner failed to repair a broken gate latch that allowed the Thorntons’ dogs to escape the property and attack Matta-Troncoso. Tyner moved for summary judgment, and the trial court determined that although Tyner breached his duty to keep the premises in repair by failing to repair the broken gate latch, summary judgment was nevertheless warranted in his favor because the Mattas made no showing that the Thorntons’ dogs had ever displayed vicious propensities or that Tyner had knowledge of such tendencies. On appeal, the Court of Appeals reversed the trial court’s ruling, concluding the trial court erred in its analysis of whether Tyner had knowledge of the dogs’ vicious propensities. Citing OCGA 51-2-7, the Court of Appeals reasoned that because there was evidence that the dogs were unleashed in violation of a local ordinance, the Mattas were not required to produce evidence that “Tyner [was] aware of the dogs’ vicious propensities.” Furthermore, the appellate court concluded Tyner could be liable under OCGA 44-7-14 because that statute did not limit a landlord’s liability to injuries occurring on a leased premises, and that there existed a genuine issue of material fact as to whether Matta-Troncoso’s injuries “arose from” Tyner’s failure to repair the gate latch. The Georgia Supreme Court granted Tyner’s petition for certiorari to address a single question: Did the Court of Appeals err by reversing the trial court’s grant of summary judgment in favor of Tyner? The Court answered that question in the affirmative, and therefore reversed the Court of Appeals. The Court determined there was no genuine issue of material fact as to whether Tyner’s failure to repair the gate latch caused Matta-Troncoso’s injuries; summary judgment in Tyner’s favor was appropriate. View "Tyner v. Matta-Tronscoso" on Justia Law

The Georgia Supreme Court granted certiorari in this case to review whether the Court of Appeals erred in reversing the grant of summary judgment to the insurer on the insured’s failure-to-settle claim. The Court also asked the parties to address whether an insurer’s duty to settle arises only when the injured party presents a valid offer to settle within the insured’s policy limits or whether, even absent such an offer, a duty arises when the insurer knows or reasonably should know that settlement within the insured’s policy limits is possible. As to this threshold issue, the Court concluded an insurer’s duty to settle arises only when the injured party presents a valid offer to settle within the insured’s policy limits. Applying the applicable rules of contract construction to correspondence from two injured parties in the instant case, the Court concluded the injured parties presented to the insurer a valid offer to settle within the insured’s policy limits but that the offer did not include any deadline for accepting the offer. Based on the undisputed evidence, as a matter of law, the insurer did not act unreasonably in failing to accept the offer before it was withdrawn by the injured parties. As the insurer was entitled to summary judgment, the Court reversed the decision of the Court of Appeals. View "First Acceptance Insurance Company of Georgia, Inc. v. Hughes" on Justia Law

Justin Tuggle was tried by jury and convicted of murder and related offenses in connection with the stabbing and beating death of Kevin Harmon. He appealed, alleging, among other things, that the trial court erred in admitting a hearsay statement of a co-defendant at trial, and erred in denying his motion for mistrial. Largely, Tuggle argued the prosecutor made an impermissible argument in his closing arguments to the court, and a curative instruction to the jury was not given. The Georgia Supreme Court found that because the parties' closing arguments were not transcribed, and because the trial court made no finings as to what the State argued, Tuggle could not how the State made an impermissible argument. Tuggle also contended the trial court failed to exercise discretion in sentencing, specifically because it sentenced Tuggle and his co-indictees to the same sentence. The Supreme Court could not say the trial court failed to exercise its discretion during sentencing. It therefore affirmed Tuggle's conviction and sentence. View "Tuggle v. Georgia" on Justia Law

In February 2015, Larry Stanford was convicted of two counts of malice murder in connection with the stabbing deaths of his wife, Peggy Stanford, and Phillip Leaks. On appeal, Stanford contended insufficient evidence was presented to support a finding of guilt. Finding the evidence sufficient to support his convictions, the Georgia Supreme Court affirmed. View "Standford v. Georgia" on Justia Law

A jury found Coleman Crouch guilty of malice murder, felony murder, aggravated assault, and concealing the death of another person in connection with the fatal shooting of Ruben Miranda and Shaland McConnell. On appeal, Crouch argued the trial court abused its discretion in excluding evidence of the mental health problems of his co- defendant, Thomas Andrew Kelly, and Kelly’s mental state at the time of the shootings. Crouch also contended his trial counsel was ineffective in failing to develop and adduce such evidence. Finding no reversible error, the Georgia Supreme Court affirmed. View "Crouch v. Georgia" on Justia Law