Justia Georgia Supreme Court Opinion Summaries

The case revolves around Kenneth Maurice Isaac, who was convicted of malice murder and other crimes related to the shooting death of Reginald Roberts. Isaac was indicted on five counts, including malice murder, felony murder, aggravated assault, possession of a firearm during the commission of a felony, and violation of the Street Gang Terrorism and Prevention Act. He was found guilty on all counts and sentenced to life in prison with the possibility of parole, along with additional consecutive sentences for the possession and street gang offenses. Isaac filed a motion for a new trial, which was denied by the trial court.The case was previously reviewed by a lower court, which denied Isaac's motion for a new trial. Isaac had argued that his trial counsel rendered ineffective assistance by refusing to allow him to testify in his own defense and that the trial court erred by declining to instruct the jury on impeachment of a witness through bias toward a party.The Supreme Court of Georgia affirmed the lower court's decision. The court found that Isaac failed to show that his trial counsel provided constitutionally ineffective assistance. Even if Isaac had testified, the court concluded that there was not a "reasonable probability" that the result of the proceeding would have been different given the strong evidence of Isaac's guilt. The court also found that the trial court did not err in declining to give a charge on impeachment of a witness through bias toward a party, as the charge was substantially covered by the charge actually given. View "ISAAC v. THE STATE" on Justia Law

David and Catherine Floam, residents of Cobb County, Georgia, sought a declaratory judgment against the Cobb County Commission, arguing that the Commission had unconstitutionally altered district boundaries that had been established by the General Assembly in 2022. The Floams argued that the Commission's amendment, which changed their voting district, exceeded the County's Home Rule powers under the Georgia Constitution. The trial court ruled in favor of the Floams, finding that the Commission's amendment did indeed exceed its Home Rule powers.On appeal, the Supreme Court of Georgia reversed the trial court's decision. The Supreme Court found that while the Floams had constitutional standing to challenge the Commission's amendment, they did not demonstrate any uncertainty regarding their future conduct that warranted declaratory relief. The court concluded that the Floams' claim was an attempt to enforce accrued rights and guide the future conduct of the defendants, which is insufficient to state a claim for declaratory relief. Therefore, the Supreme Court reversed the trial court's decision, without reaching the merits of the constitutional arguments. View "COBB COUNTY v. FLOAM" on Justia Law

The case involves Rodrigues Platt, who was convicted for crimes related to the shooting death of David Jones, Jr. The crimes occurred on June 16, 2009, and Platt, along with two others, was indicted for malice murder, felony murder predicated on aggravated assault, aggravated assault, armed robbery, burglary, and possession of a firearm during the commission of a crime. A jury found Platt guilty on all counts in August 2011, and he was sentenced to life in prison for malice murder, two concurrent twenty-year terms for armed robbery and burglary, and a consecutive five-year term for the firearms offense. Platt filed a motion for a new trial in August 2011, which was denied in September 2023.Platt appealed his convictions, arguing that the trial court should have granted a mistrial due to the State’s failure to disclose the inconclusive test results of a hair sample from a critical witness against him who was also a possible suspect. He also argued that the court should have granted a mistrial based on the State’s belated disclosure that Platt’s initial custodial interview had been recorded despite previously representing otherwise. Platt also argued that the trial court should have taken some curative action when the prosecutor improperly identified him for testifying witnesses, and that the cumulative prejudice of these errors warrants a new trial.The Supreme Court of Georgia concluded that Platt failed to establish that a mistrial was necessary to preserve his right to a fair trial, that any curative action was necessary based on the prosecutor’s identification of him, or that any errors cumulatively prejudiced him. Therefore, the court affirmed the lower court's decision. View "PLATT v. STATE" on Justia Law

Two former police officers, John Powell and Brian Scott, were indicted for violating their oaths of office under OCGA § 16-10-1. The indictment alleged that they failed to uphold the Constitution of the United States as interpreted by Brady v. Maryland by not conducting investigations into allegations of police misconduct. The officers filed a general demurrer, arguing that the indictment failed to adequately charge them with any offense against the laws of Georgia, and that the oath-of-office statute was unconstitutionally vague as applied to the facts of the case. The trial court denied the demurrer, concluding that the allegations would constitute conduct violative of the oaths of office taken by the officers.The Supreme Court of Georgia reviewed the trial court's ruling on the general demurrer de novo. The court agreed with the officers that the trial court's ruling regarding the sufficiency of the indictment was erroneous, and their general demurrers should have been granted. The court found that the indictment alleged that the officers committed the crimes in a specific way that was legally impossible. The court concluded that the indictment against the officers could not withstand a general demurrer and reversed the trial court's denial of the general demurrers to the indictment. The court did not reach the officers' constitutional challenge or the speedy-trial issue also before them on appeal. View "POWELL v. STATE" on Justia Law

The case involves James Graham Ward who was convicted for felony murder and other crimes related to two shootings that occurred on March 24, 2021, one of which resulted in the death of Brian Belin. Ward was indicted for multiple counts including malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. He was found guilty on several counts and sentenced to life in prison without the possibility of parole, plus a total of 20 consecutive years for other counts. Ward filed a timely motion for a new trial, which was denied by the trial court.Ward appealed his convictions, arguing that the trial court erred in denying his request to charge the jury on voluntary manslaughter, in denying his motion for a directed verdict on certain counts, and that his trial counsel rendered ineffective assistance. The Supreme Court of Georgia, after reviewing the evidence and arguments, found no merit in Ward's claims and affirmed his convictions. The court held that there was not even slight evidence to support a charge of voluntary manslaughter, the evidence was sufficient to support Ward’s convictions for aggravated assault and possession of a firearm, and Ward failed to prove that his counsel performed deficiently. View "WARD v. STATE" on Justia Law

Truman Harry Smith was convicted of felony murder and other charges related to the shooting death of Johnny Crawford. Smith claimed self-defense, stating that he shot Crawford due to fear for his life, and argued that he suffered from post-traumatic stress disorder (PTSD). The jury rejected Smith's defense and he was sentenced to life in prison plus five years for possession of a firearm during the commission of a felony. Smith appealed, contending that the trial court should have allowed him to testify about his PTSD diagnosis and should not have permitted the State to impeach him with a prior military charge.The trial court had denied Smith's motion for a new trial, and the Supreme Court of Georgia granted Smith's application for interlocutory appeal. Smith argued that his PTSD diagnosis should have been admissible under a hearsay exception for statements made for the purpose of medical diagnosis. However, the Supreme Court of Georgia ruled that this exception does not apply to medical diagnoses themselves, but to statements patients make to medical professionals to aid in their diagnosis or treatment.Smith also contended that the trial court erred by allowing the State to impeach him with a prior military charge. The Supreme Court of Georgia found that even if it was an error to allow the State to ask about the charge, the error was harmless given the overall evidence. The court affirmed Smith's convictions and sentence. View "Smith v. State" on Justia Law

Andrew Thomas Huber was convicted of felony murder predicated on aggravated assault in relation to the shooting death of Daniel Raburn. Huber, along with his accomplices Thomas Wayne Harper and Brandilee Nicole Woodard-Brady, were indicted on charges of malice murder, felony murder predicated on aggravated assault, and three counts of aggravated assault against Raburn. Prior to Huber's trial, Harper was convicted of voluntary manslaughter and aggravated assault, and Woodard-Brady pleaded guilty to voluntary manslaughter. A jury found Huber not guilty of malice murder but guilty of all the remaining counts against him. The trial court sentenced Huber to life in prison without the possibility of parole for felony murder. Huber filed a motion for a new trial, which was denied by the trial court.Huber appealed his conviction to the Supreme Court of Georgia, arguing that the evidence was insufficient to support his felony murder conviction, his trial counsel rendered ineffective assistance, and the trial court committed plain error in instructing the jury on simple assault and voluntary manslaughter. The Supreme Court of Georgia affirmed the lower court's decision. The court found that the evidence, when viewed in the light most favorable to the jury’s verdict, was sufficient to support Huber’s conviction for felony murder predicated on aggravated assault. The court also found that Huber's trial counsel did not render ineffective assistance and that the trial court did not commit plain error in its instructions to the jury. View "HUBER v. STATE" on Justia Law

The case involves Charles Michael Sconyers who was convicted for malice murder and cruelty to children in the first degree, in relation to the death of 23-month-old Lincoln Davitte. The child died from blunt-force trauma to his skull. Evidence presented at trial showed that Sconyers and the child's mother, Chelsea Finch, lived together and that the child sustained a severe head injury while under Sconyers' sole care. Sconyers claimed the injury was due to a ground-level fall on the patio, but several medical experts testified that the injury was inconsistent with such a fall.Sconyers was indicted for malice murder, two counts of felony murder, and one count each of aggravated assault and cruelty to children in the first degree. He was found guilty on all counts and sentenced to life in prison for malice murder and concurrent 20-year prison terms for aggravated assault and cruelty to children. The felony murder counts were vacated by operation of law. Sconyers filed a motion for a new trial, which was denied by the trial court. He then appealed to the Supreme Court of Georgia.Sconyers raised four issues on appeal: the trial court's repeated allowance of evidence of previous injuries to the child without cautioning the jury that the parties agreed Sconyers did not cause those injuries; the jury instruction about “prior difficulties” between Sconyers and the child without limiting what evidence qualified as prior difficulties; the admission of hearsay statements allegedly made by Finch; and the prosecution's alleged improper impeachment of Finch. The Supreme Court of Georgia affirmed the trial court's decision, rejecting all of Sconyers' arguments. View "Sconyers v. State" on Justia Law

Kiervon Armani Hooks was convicted of felony murder and possession of a firearm during the commission of a felony, both charges stemming from the shooting death of Brandon Ray Foster. The incident occurred on September 26, 2017, and Hooks was indicted on December 18, 2017. The jury found Hooks guilty of all counts during a trial held from February 4-6, 2019. He was sentenced to life without parole for felony murder and an additional five years for possession of a firearm during the commission of a felony. Hooks filed a motion for a new trial, which was denied by the trial court.Hooks appealed his conviction, arguing that the evidence was insufficient to sustain his convictions as no physical evidence or eyewitness testimony linked him to the crime scene. He also argued that the State did not present enough evidence to exclude the possibility that someone else shot Foster. However, the Supreme Court of Georgia affirmed his convictions.The court found that the evidence was constitutionally sufficient to uphold the convictions. The evidence included Foster's statement that "Buddha" shot him, with multiple witnesses identifying Hooks as the only person they knew by that nickname. Additionally, a .40-caliber shell casing was found near the building where Hooks was staying, and Hooks admitted to being in the building except for when he stepped out to smoke a cigarette. The court concluded that this evidence, viewed in the light most favorable to the verdicts, authorized the jury to find Hooks guilty of the felony murder of Foster and possession of a firearm during the commission of that crime. View "Hooks v. State" on Justia Law

Bryan Keith Schmitt was convicted of malice murder for the death of Hamid Jahangard, who died after being hit by Schmitt’s car. Schmitt was indicted on charges of malice murder, two counts of felony murder, and two counts of aggravated assault. The jury found Schmitt guilty on all counts, and he was sentenced to life in prison with the possibility of parole. Schmitt appealed, arguing that the trial court erred by denying his request to instruct the jury on the defense of accident.The Supreme Court of Georgia found that the trial court did err in denying Schmitt's request for an accident defense instruction. The court noted that there was at least slight evidence supporting Schmitt's claim that the collision was an accident, including his own testimony and expert testimony that he veered away from Jahangard before the collision. The court also noted that the trial court's instruction to the jury to disregard accident as a key legal principle was problematic, as it may have led the jury to disregard Schmitt's accident defense.The court concluded that the trial court's error was not harmless, as the evidence of Schmitt's criminal intent was disputed and not overwhelming. Therefore, the court reversed Schmitt's conviction. The court also found that the trial court erred in declining the accident instruction for the related counts of felony murder and aggravated assault, and reversed those verdicts as well. However, the court noted that the evidence was legally sufficient to sustain Schmitt’s conviction, and so the State may retry him. View "SCHMITT v. STATE" on Justia Law