Justia Georgia Supreme Court Opinion Summaries

Rajonte McGruder was convicted of malice murder in the death of Kenneth Quarterman, Jr., aggravated assault against Lewis Brown III, and other crimes in connection with a drive-by shooting in June 2013. On appeal, McGruder argued the evidence admitted at trial was legally insufficient to support his convictions. The Georgia Supreme Court found the evidence was sufficient to authorize the jury to find beyond a reasonable doubt that McGruder was guilty of the crimes of which he was convicted, and therefore affirmed. View "McGruder v. Georgia" on Justia Law

Appellant John Taylor was tried and convicted of malice murder and related offenses in connection with the February 2011 death of Gene Musgrave and aggravated assault of Robert Sauls. Taylor appealed, alleging: (1) that he received ineffective assistance of counsel, (2) that the trial court erred during closing argument; and (3) that his indictment was fatally defective. Finding no reversible error, the Georgia Supreme Court affirmed. View "Taylor v. Georgia" on Justia Law

This case arose from a January 2013 roadway altercation between George Ebinger and another motorist, Logan Lord, that came to a head in a shopping center parking lot. Lord claimed to have suffered injuries to his arms when Ebinger hit him with a shovel. Lord testified at trial that he initially held a knife at his side and then began to stab at Ebinger only after Ebinger began swinging at him with the shovel. Ebinger testified that Lord began attacking him with a knife as soon as he exited his vehicle and that he struck Lord with the shovel only to defend himself. Warden Ahmed Holt appealed the grant of habeas relief to Ebinger, who was tried in 2014 by jury and convicted of one count of aggravated assault. The habeas court granted relief on the basis of ineffective assistance of both trial and appellate counsel. The Warden argued the habeas court erred by improperly reaching the merits of the ineffective assistance of trial counsel claims and by finding that Ebinger was prejudiced by appellate counsel’s alleged deficiencies. The Georgia Supreme Court reversed because Ebinger’s failure to complete the record with relevant evidence from the trial proceedings was fatal to all of the claims for which he was granted habeas relief. View "Holt v. Ebinger" on Justia Law

Dustin Putnal was been indicted for one count each of malice murder, aggravated battery, and aggravated sexual battery and two counts each of felony murder and cruelty to children in the first degree in connection with the death of Ella Grayce Gail Pointer, a minor, on or about October 28 or 29, 2016. The State sought the death penalty. After the trial court issued an order denying Putnal’s motion to proceed ex parte and under seal with regard to his requests for defense-retained mental health experts to gain access to him in the detention center where he is incarcerated, Putnal obtained a certificate of immediate review from the trial court and filed an application for interlocutory appeal with the Georgia Supreme Court. The Supreme Court granted Putnal’s application in an order directing the parties to address: “Whether the trial court erred in denying Putnal’s motion to proceed ex parte and under seal with regard to matters pertaining to his expert mental health investigation.” The Court also directed that, in addressing this question, the parties discuss Zant v. Brantley, 411 SE2d 869 (1992), in which the Court previously held that the State was not entitled to be present at a hearing concerning the defendant’s request for an access order similar to the access orders involved in Putnal’s case. After review of that briefing, the Supreme Court concluded the issue presented in this case was controlled by Brantley. Therefore, the Court reversed the trial court order from which Putnal appealed, and remanded this case for further proceedings. View "Putnal v. Georgia" on Justia Law

The Georgia Supreme Court granted certiorari to consider whether the warrantless search of Richard Caffee resulting in the discovery of marijuana was authorized by an exception to the Fourth Amendment’s warrant requirement. The Court of Appeals concluded that the warrantless search was permissible because it was supported by probable cause to believe that marijuana would be found on Caffee. “Absent consent, probable cause generally is a necessary condition to support a warrantless search of a person, but it is not by itself sufficient; a warrantless search must also fall within a recognized exception to the warrant requirement.” To the extent the Court of Appeals suggested otherwise, the Supreme Court determined it was wrong. Nevertheless, the Supreme Court affirmed because the warrantless search was permissible as a search incident to arrest (even though it preceded the formal arrest) as the police officer had developed probable cause to arrest Caffee for possession of marijuana before conducting the search. View "Caffee v. Georgia" on Justia Law

Appellant Latisha McCoy was charged with driving under the influence of marijuana to the extent it was less safe to drive after she was stopped at a roadblock in Henry County, Georgia. She moved to suppress all evidence obtained from the stop and arrest on the ground that the roadblock violated the Fourth Amendment. The trial court denied McCoy’s motion, and following a bench trial, found her guilty. She appealed; the Court of Appeals affirmed the trial court’s denial of her motion to suppress. The Georgia Supreme Court granted McCoy’s petition for certiorari on whether the Court of Appeals erred in its application of LaFontaine v. Georgia, 497 SE2d 367 (1998), in determining whether the roadblock was reasonable under the Fourth Amendment, in particular the factor that considered the screening officer’s training and experience. Although the Supreme Court did not follow the analysis employed by the Court of Appeals, it affirmed the judgment, and in doing so, clarified the factors needed to determine whether a roadblock is reasonable under the Fourth Amendment. View "McCoy v. Georgia" on Justia Law

Ashleigh Ricks appealed the denial of her 2017 motion for an out-of-time appeal of her guilty-plea conviction for felony murder. The Georgia Supreme Court reversed, concluding that the trial court was without jurisdiction to decide the motion. View "Ricks v. Georgia" on Justia Law

This appeal stemmed from the Forsyth County, Georgia Probate Court’s finding that Emanuel Gladstone breached his fiduciary duty as conservator for his incapacitated wife, Jacqueline Gladstone. The court entered a judgment against Gladstone and his surety, Ohio Casualty Insurance Company, for $167,000 “on the settlement of accounts and as damages” and $150,000 in punitive damages. The Court of Appeals affirmed the probate court’s judgment. The Georgia Supreme Court granted Ohio Casualty’s petition for certiorari, and the Georgia Supreme Court directed the parties to address two questions: (1) whether the appellate court erred in holding that a conservator’s bond covered punitive damages even though such damages were not expressly provided for under OCGA 29-5-40 et seq. or under the provisions of the bond itself; and (2) if a conservator’s bond did cover punitive damages, did the Court of Appeals err in holding that because the probate court complied with OCGA 29-5-92 (b) (4) in imposing sanctions against the petitioner, compliance with the procedures for imposing punitive damages under OCGA 51-12-5.1 was not required. The Supreme Court answered the first question in the affirmative, rendering the second question moot. View "In re Estate of Gladstone" on Justia Law

The Georgia Supreme Court granted certiorari in this case to address whether Georgia’s new Juvenile Code required a party to follow the interlocutory appeal procedures laid out in OCGA 5-6-34 (b) when appealing an order concerning the transfer of a case from juvenile to superior court. The Court held that it did not and, in so doing, reversed the decision of the Court of Appeals and remanded the case to be decided on the merits. View "In the Interest of K.S., a child" on Justia Law

This case was a “John Doe” appeal from the denial of a motion to seal the records of a criminal case pursuant to OCGA 35-3-37 (m). In July 2006, Doe pled guilty to possession of marijuana as a first-time drug offender and was sentenced to five years on probation without entry of a judgment of guilt The Court of Appeals transferred the appeal to the Georgia Supreme Court on the sole basis of the Supreme Court’s exclusive appellate jurisdiction in "all cases in which the constitutionality of a law, ordinance, or constitutional provision has been drawn in question." After review, the Supreme Court concluded this appeal did not invoke its Court’s constitutional-question jurisdiction, and accordingly, returned the case to the Court of Appeals. View "Doe v. Georgia" on Justia Law