Justia Georgia Supreme Court Opinion Summaries

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

Appellant George Edward Price was convicted of malice murder in connection with the shooting death of his estranged wife, Jackie Price. Appellant argued on appeal: (1) his statement to law enforcement should have been excluded at trial; (2) that the trial court failed to consider his motion for new trial on the “general grounds;” and (3) that trial counsel was ineffective. Finding no error, the Georgia Supreme Court affirmed. View "Price v. Georgia" on Justia Law

Dallas Beck was convicted of felony murder and possession of a weapon during the commission of a crime in connection with the shooting death of Corey Liverpool. On appeal, Beck contended: (1) the trial court erred by refusing to charge the jury on voluntary manslaughter; (2) Beck was denied a fair trial because jurors considered extrajudicial information during deliberations in reaching a verdict; and (3) that Beck was denied a fair trial because the trial court refused to admit certain evidence of specific instances of the victim’s violent conduct, reputation evidence of the victim, and evidence of the victim’s violence-themed tattoos. The Georgia Supreme Court determined that a changed Evidence Code, OCGA 24-6-606 (b), governed what was or was not admissible to sustain or impeach a verdict. Here, despite the Court's admonition in Davis v. Georgia, 787 SE2d 221 (2016), the parties did not brief or argue the meaning of Rule 606 (b) at the motion for new trial hearing, and the trial court did not apply it when addressing the jury-misconduct claim raised in Beck’s motion. Similarly, the parties did not address the new rule on appeal. "The difference between the old and new Evidence Code matters in this case." Juror C.C. offered some evidence from which the trial court could conclude that extraneous prejudicial information was brought to the jury’s attention when she testified that sentencing information did not come from other jurors and that it was “given to” them. The Court vacated the judgment, and remanded the matter for further proceedings. View "Beck v. Georgia" on Justia Law

Alandis Jackson appealed the denial of his motion for new trial following his convictions for malice murder and other crimes in connection with the death of Steven Lewis. On appeal, Jackson argued: (1) the evidence was insufficient to support his conviction for burglary; (2) the trial court committed plain error when it charged the jury regarding circumstantial evidence, evidence of good character, and prior statements; (3) he received ineffective assistance of counsel due to his trial attorney’s failure to object to such instructions; and (4) 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 it affirmed the trial court’s denial of his motion for a new trial. View "Jackson v. Georgia" on Justia Law

During his 2007 trial, Derrick Cartwright raised an alibi defense to charges of murder and other crimes in connection with the shooting death of Kevin Stafford. Cartwright was convicted and sentenced to serve life in prison plus five years. On direct appeal, he claimed among other things that his trial counsel provided ineffective assistance by failing to challenge a police detective's testimony that Cartwright had not mentioned his alibi during his post-arrest police interview. The Georgia Supreme Court affirmed Cartwright’s convictions, rejecting his claim that his trial counsel provided ineffective assistance by failing to introduce the testimony, finding Cartwright had not shown prejudice because at the motion for new trial hearing, he failed to call the detective as a witness or introduce a transcript of the detective’s preliminary hearing testimony. Cartwright then filed a petition for habeas corpus, alleging among other things that his appellate counsel provided ineffective assistance by failing to introduce evidence to prove trial counsel’s ineffectiveness in failing to impeach the detective. The habeas court denied the petition. The Supreme Court granted Cartwright’s application to appeal for consideration of whether the habeas court erred in ruling that Cartwright had not shown that his appellate counsel provided ineffective assistance. The Supreme Court concluded the habeas court’s ruling was erroneous, and therefore reversed the denial of habeas relief. View "Cartwirght v. Caldwell" on Justia Law