Justia Georgia Supreme Court Opinion Summaries

Saul Castillo-Velasquez appealed his convictions for malice murder and possession of a firearm during the commission of a crime stemming from the 2013 shooting death of Silverio Acosta. On appeal, Castillo-Velasquez contended the trial court erred by admitting other-act evidence under OCGA 24-4-404 (b) and by admitting Acosta’s bloody clothes into evidence. He also claimed he received ineffective assistance of counsel. The Georgia Supreme Court concluded his claims had no merit and affirmed. View "Castillo-Velazquez v. Georgia" on Justia Law

Jerome Burgess was convicted in 2010 by jury of felony murder, three counts of aggravated assault, and possession of a firearm during the commission of a crime, and we affirmed his convictions. Burgess later filed a petition for a writ of habeas corpus, alleging that appellate counsel was ineffective for failing to argue on appeal that: (1) trial counsel was ineffective for failing to cross examine effectively a testifying co-defendant; and (2) the State committed a Brady v. Maryland, 373 U.S. 83 (1963) violation for failing to disclose impeachment evidence against that co-defendant. The habeas court denied Burgess relief. The Georgia Supreme Court granted Burgess’s application for a certificate for probable cause, but ultimately affirmed, finding the habeas court correctly rejected Burgess’s claims. View "Burgess v. Hall" on Justia Law

The Superior Court of Jenkins County Georgia granted Jeffrey Watson’s petition for a writ of habeas corpus and set aside his convictions for family violence aggravated battery based on its finding that Watson’s plea counsel provided him with ineffective assistance in connection with the entry of his guilty plea. The Warden did not challenge the habeas court’s findings concerning plea counsel’s deficient performance. Rather, the Warden contended only that the habeas court, by “conflating” deficient performance and prejudice, failed to properly analyze whether Watson was prejudiced by counsel’s deficient performance. The Georgia Supreme Court found the deficient performance and prejudice prongs of the Strickland v. Washington, 466 U. S. 668 (1984) test were two separate inquiries, and the habeas court was, required to determine whether Watson had shown “that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial.” Because the habeas court failed to properly analyze the prejudice prong, its order lacked a factually supported legal conclusion essential to its ruling on Watson’s ineffective assistance of counsel claim and essential to the Supreme Court’s appellate review of that ruling. Therefore, the Court vacated the habeas court’s judgment and remanded this case to the habeas court with instruction to enter a new order consistent containing the requisite findings of fact and conclusions of law. View "Dozier v. Watson" on Justia Law

Alandis Jackson was convicted by jury of malice murder and other crimes in connection with the 2014 death of Steven Lewis. Jackson appealed the denial of his motion for a new trial, arguing the evidence was insufficient to support his conviction for burglary; that the trial court committed plain error when it charged the jury regarding circumstantial evidence, evidence of good character, and prior statements; that he received ineffective assistance of counsel due to his trial attorney’s failure to object to such instructions; and that the false imprisonment count should have merged with his conviction for the aggravated assault of Titus Robinson. The Georgia Supreme Court determined each of these enumerations of error were meritless and affirmed the trial court’s denial of his motion for a new trial. View "Jackson v. Georgia" on Justia Law

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, however, 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 concluded 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

This case came to the Georgia Supreme Court by way of three certified questions from the United States Court of Appeals for the Eleventh Circuit. As the receiver of the Buckhead Community Bank, the Federal Deposit Insurance Corporation (FDIC) sued nine former directors and officers of the Bank in federal district court, alleging that the former directors and officers were negligent and grossly negligent under Georgia law for their approval of ten commercial real-estate loans. At the conclusion of the trial, the jury found that some of the former directors and officers were negligent in approving four of ten loans at issue, and awarded the FDIC $4,986,993 in damages. The district court entered a final judgment in that amount and held the former directors and officers jointly and severally liable. They timely appealed to the Eleventh Circuit, arguing the district court erred by failing to instruct the jury on apportionment, which, they say, was required by OCGA 51-12-33 because purely pecuniary harms (such as the losses at issue here) were included within “injury to person or property” under Georgia’s apportionment statute. Concluding that these arguments required answers to questions of law that “have not been squarely answered by the Georgia Supreme Court or the Georgia Court of Appeals,” the Eleventh Circuit certified questions of Georgia law to the Georgia Supreme Court. The Georgia Court concluded OCGA 51-12-33 did apply to tort claims for purely pecuniary losses against bank directors and officers, but did not abrogate Georgia’s common-law rule imposing joint and several liability on tortfeasors who act in concert insofar as a claim of concerted action invokes the narrow and traditional common-law doctrine of concerted action based on a legal theory of mutual agency and thus imputed fault. View "Federal Deposit Insurance Corporation v. Loudermilk" on Justia Law

According to precedent, Georgia superior courts had jurisdiction to review by writ of certiorari under OCGA 5-4-1 not only the judicial decisions of inferior courts, but also the quasi-judicial decisions of other instrumentalities and officers of state and local government. In Gould v. Housing Authority of the City of Augusta, 808 SE2d 109 (2017), a divided panel of the Court of Appeals held that the certiorari jurisdiction of the superior courts extended to decisions of municipal housing authorities discontinuing the provision of housing assistance under Section 8 of the Housing Act of 1937. The Georgia Supreme Court brought the case up to consider whether the writ of certiorari reached so far, and concluded that it did not. Therefore, the Court reversed the judgment of the Court of Appeals. View "Housing Authority of the City of Augusta v. Gould" on Justia Law

Albert and Ashley Debelbot were convicted of malice murder for the death of their infant daughter, McKenzy. The Debelbots each argued the evidence was insufficient to sustain their convictions, that their respective trial attorneys rendered constitutionally ineffective assistance, and that their convictions cannot stand for other reasons. The Georgia Supreme Court concluded that the evidence was sufficient to support the convictions of both Albert and Ashley. But while the Court was “deeply troubled” by at least two of the claims of ineffective assistance of counsel, the nature of the trial court record prevented meaningful review of all of those claims. Therefore, the Court vacated and remanded for further proceedings. View "Debelbot v. Georgia" on Justia Law

Following a jury trial, Jerome Coast was convicted of malice murder and possession of a firearm by a convicted felon during the commission of a crime in connection with the shooting death of Michael James. Coast appealed, contending the trial court abused its discretion by denying his request to represent himself on the sole basis that the request came after his trial had begun. Finding no reversible error, the Georgia Supreme Court affirmed. View "Coast v. Georgia" on Justia Law

Michael Blaine was tried on a 38-count indictment and convicted of numerous offenses, including murder, in connection with a string of robberies that took place between October 2005 and September 2006. Blaine appealed, arguing that the prosecutor made improper statements during closing arguments, that he was denied his rights to due process and access to the courts, and that he was denied effective assistance of counsel. Finding no error, the Georgia Supreme Court affirmed. View "Blaine v. Georgia" on Justia Law