Justia Georgia Supreme Court Opinion Summaries

Appellant Anthony Lee Douglas was convicted of malice murder and associated offenses in connection with the shooting deaths of Keith Davis and Charles Avent and the wounding of Sheldon Thomas. On appeal, Appellant contended that the trial court erroneously denied his motion to suppress and improperly admitted other acts evidence under OCGA 24-4-404 (b). Though the Georgia Supreme Court concluded Appellant was erroneously sentenced, the Court otherwise affirmed, and remanded for resentencing. View "Douglas v. Georgia" on Justia Law

Appellant Clifford White was found guilty of murdering his wife, Linda in 2008. She was discovered by appellant’s brother-in-law in a freezer, partially dressed with a bag over her head. The cause of death was listed as blunt force trauma to the head. Appellant appealed his conviction, arguing the evidence was insufficient to sustain his malice murder conviction, and that he received ineffective assistance of trial counsel. Finding no reversible error, the Georgia Supreme Court affirmed. View "White v. Georgia" on Justia Law

Stephanie Stephens appealed several convictions stemming from the death of her child, Jewell, from cocaine poisoning. Stephens was ultimately sentenced on only one count, felony murder predicated on possession of cocaine with intent to distribute. She argued the evidence was insufficient on that count because the State failed to prove a nexus between the underlying felony and her child’s death. The Georgia Supreme Court rejected that argument, and the same argument in the appeal of her co-defendant, with whom Stephens was tried jointly. Her remaining arguments addressed counts that the trial court merged or effectively vacated, and thus are moot. As such, the Supreme Court affirmed the conviction. View "Stephens v. Georgia" on Justia Law

Darrell Hendrix was convicted by jury for felony murder, drug-related and gang-related crimes. On appeal to the Georgia Supreme Court, he contended the evidence was insufficient and that the trial court erred by admitting certain witness testimony pursuant to OCGA 24–8–804 (b) (5). After review of the specific facts of this case, the Georgia Court found the evidence admitted was sufficient to support Hendrix’s convictions, and affirmed. View "Hendrix v. Georgia" on Justia Law

Armando Soto appealed his convictions for malice murder and other crimes in connection with the 2009 shooting death of Angelica Robledo. Soto argued on appeal to the Georgia Supreme Court that the evidence was insufficient to support his malice murder conviction, the trial court erred in failing to charge on the lesser included offenses of reckless conduct and terroristic threats, and the trial court erred in denying his motions in limine to exclude the victim’s statements about being harassed by a dangerous man and to exclude evidence about his immigration status. The Supreme Court affirmed the convictions, finding the evidence was sufficient to support Soto’s convictions and that the trial court did not err in refusing to charge on the lesser included offenses. Furthermore, the Court concluded any evidence that was admitted as a result of the trial court’s allegedly erroneous denial of Soto’s motions in limine did not affect the outcome of the trial. View "Soto v. Georgia" on Justia Law

Damion Clayton was shot and killed in a baseball park in Macon. In March 2014, a grand jury indicted Appellant Jedarrius Meadows, Roland Watson, and Trayvon Starks for malice murder and felony murder; in June, they were reindicted on those two murder charges along with aggravated assault, armed robbery, and two counts of gang activity. Appellant’s trial was severed, and his co-indictees agreed to testify for the State. Appellant challenged the trial court’s denial of his plea in bar based on double jeopardy after the court, sua sponte and over Appellant’s objection, declared a mistrial of his murder trial during jury deliberations. In its order denying the plea, the court said that the deliberations were contentious and that it declared the mistrial “in the interest of juror safety.” Having reviewed the record, the Georgia Supreme Court concluded the trial court declared the mistrial without sufficient factual support and without considering less drastic alternatives to terminating the trial. Because there was no manifest necessity for a mistrial, the Supreme Court reversed the denial of the plea in bar. View "Meadows v. Georgia" on Justia Law

Jahbari Jones appealed his convictions for malice murder and theft by taking in connection with the shooting death of his cousin, Tradae Jones. Jones argued the evidence was insufficient to sustain his convictions and that the trial court erred in instructing the jury during the separate trial on the issue of Jones’s mental competency, in excluding statements Jones made to police by telephone after the shooting and before his arrest, and in not including the lesser offenses of voluntary manslaughter and involuntary manslaughter on the verdict form. After review, the Georgia Supreme Court disagreed and affirmed the convictions. View "Jones v. Georgia" on Justia Law

In October 2005, a grand jury indicted Xavier Snelson, Jr. for the July 5, 2005 murder, felony murder and aggravated assault of Natilya Smith. In May 2006, Snelson pled guilty to the counts as alleged in his indictment. He was sentenced to life in prison for malice murder; the remaining counts were either merged into the malice murder or vacated by operation of law. Snelson appealed the denial of his motion for an out-of-time direct appeal. Finding no error, the Georgia Supreme Court affirmed the denial. View "Snelson v. Georgia" on Justia Law

Lewis Mitchell Jr. was convicted of malice murder, aggravated assault, and two counts of possession of a firearm in commission of a felony, in connection with the 2009 killing of Antonio Jermaine Mitchell (“Jermaine”) and the wounding of Desmond Jones. His amended motion for new trial was denied, and he appealed, asserting that: (1) the evidence was insufficient; (2) that the trial court erred in allowing a State’s witness to be questioned as a hostile witness; and (3) that the trial court erred in allowing speculative testimony from a forensic biologist. As part of the last enumeration, he also alleged he received ineffective assistance of counsel. Finding no reversible error, the Georgia Supreme Court affirmed Mitchell’s convictions. View "Mitchell v. Georgia" on Justia Law

Appellant Lavoris Jackson was tried jointly with Ramel Brown, and both were convicted for murder and other crimes arising out of the 2012 shooting death of victim Curtis Jordan. One witness saw both Brown and Jackson shooting their respective weapons, and she saw a third person with them whom she could not identify. The witness also saw an unidentified man shooting a shotgun out the window of a truck that was passing by. That witness saw the victim running and then falling to the ground, after which she saw Jackson, Brown, and the third person fleeing on foot in the direction taken by the truck. The victim collapsed and died at the scene. Appellant challenged the sufficiency of the evidence to support the convictions, arguing that because the evidence established that the victim died as a result of a shotgun wound, and no evidence was presented that he fired a shotgun at the victim, he could not be found guilty of the crimes charged. He also argued that even though two witnesses testified they saw appellant holding a handgun, only one witness testified consistently with her earlier statement that appellant fired the handgun. The Georgia Supreme Court affirmed the convictions, finding that appellant “ignores that sufficient evidence was presented to support his convictions, at least as a party to the crimes charged.” View "Jackson v. Georgia" on Justia Law