Justia Georgia Supreme Court Opinion Summaries

After their property in DeKalb County was annexed by the City of Atlanta, two parents sought to enroll their children in Atlanta Public Schools (APS). APS, however, denied enrollment, citing a 2021 Georgia law (SB 209) that prevents the expansion of APS boundaries to include newly annexed areas unless specifically authorized. The City of Atlanta had approved the annexation and expressed its intent for the APS boundaries to expand accordingly, but APS maintained that SB 209 prohibited such an extension.The parents and the City of Atlanta filed a petition for declaratory and injunctive relief against the State of Georgia, arguing that SB 209 was unconstitutional under the Georgia Constitution’s Single Subject Rule. The case was initially filed in Fulton County, transferred to DeKalb County, and then refiled in Fulton County against the State after the plaintiffs voluntarily dismissed the DeKalb action. The DeKalb County School District (DCSD) was allowed to intervene as a plaintiff. The trial court denied motions to dismiss, found that the plaintiffs had standing, determined there was a justiciable controversy, and ruled that SB 209 violated the Single Subject Rule, granting declaratory and injunctive relief to the plaintiffs.On appeal, the Supreme Court of Georgia reviewed whether the trial court had jurisdiction to grant relief. The Supreme Court of Georgia held that the plaintiffs failed to establish an actual or justiciable controversy with the State, as the alleged harm stemmed from APS’s actions, not from any enforcement by the State. Because the dispute did not involve the parties before the court, the Supreme Court of Georgia vacated the trial court’s judgment and remanded the case with instructions to dismiss the petition. View "PILATO v. STATE OF GEORGIA" on Justia Law

The case concerns a man who lived with his father in Barrow County, Georgia, and was accused of killing a family friend who often stayed at their home. After the friend’s disappearance, the accused made suspicious statements to his father, and the friend’s body was later found in the trunk of his own car, having been shot multiple times. The accused was apprehended after fleeing from law enforcement, and during post-arrest interviews, he admitted to the killing and provided details that were corroborated by physical evidence. At trial, he testified that he shot the victim after a confrontation related to past sexual abuse and introduced evidence about his methamphetamine use and its effects.A Barrow County grand jury indicted the accused on multiple charges, including malice murder, felony murder, aggravated assault, firearm possession during a felony, concealing a death, and methamphetamine possession. After a jury trial in the Superior Court of Barrow County, he was found guilty on all counts. The court sentenced him to life plus eighteen years in prison, with certain counts merging or being vacated as a matter of law. The defendant’s motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed three main claims: the failure to give a jury instruction on voluntary intoxication, the admission of prior-act evidence under Georgia’s Rule 404(b), and the admission of his post-arrest statements. The Court held that the trial court properly declined the requested intoxication instruction because it misstated the law, any error in admitting the prior-act evidence was harmless given the overwhelming evidence of guilt, and the admission of the defendant’s statements did not violate due process because there was no evidence of police coercion. The Supreme Court of Georgia affirmed the convictions. View "WOSCHULA v. THE STATE" on Justia Law

The case concerns the killing of Regina Trotter, who lived in Alabama with Micah Blake Taylor and another individual. On January 31, 2021, Taylor took Trotter’s van without her permission. After returning the van, Trotter told Taylor he could no longer stay at her home. She agreed to drive Taylor and Jenae Dickinson back to Dickinson’s residence. During the drive, Taylor strangled Trotter after Dickinson directed Trotter down a dirt road. Taylor then pulled Trotter into the back of the van, and after a struggle, removed her from the vehicle. Trotter’s body was found the next day with evidence of strangulation and sharp-force injuries. Physical evidence, including DNA and items found at the scene, linked Taylor to the crime. Taylor was later found asleep in Trotter’s stolen van.A Heard County grand jury indicted Taylor and Dickinson. Dickinson pleaded guilty to lesser charges and testified against Taylor. In March 2023, a jury in the Superior Court of Heard County found Taylor guilty of malice murder and related offenses. He was sentenced to life without parole plus a consecutive ten-year term. Taylor’s motion for a new trial was denied by the trial court in September 2024. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Taylor’s claims that the trial court erred in admitting evidence obtained from his Facebook account and cell phone records, arguing the warrants lacked probable cause. The Court held that even if the warrants were deficient, any error was either not plain or was harmless beyond a reasonable doubt because the challenged evidence was cumulative of other properly admitted evidence and the evidence of Taylor’s guilt was overwhelming. The Court affirmed the judgment of the trial court. View "TAYLOR v. THE STATE" on Justia Law

Two defendants were indicted for murder, multiple violations of Georgia’s Street Gang Terrorism and Prevention Act, and other crimes related to the shooting death of a victim. The State alleged that the defendants were associated with the Bloods gang and committed the murder to further the gang’s interests. During the investigation, law enforcement obtained extensive Instagram records believed to be linked to the defendants, containing messages, photos, and videos that the State argued demonstrated gang affiliation. One defendant moved to exclude certain social media posts from his trial, arguing they were irrelevant, unfairly prejudicial, duplicative, and otherwise inadmissible, though he did not cite specific legal authority.The Superior Court of Hall County held a hearing on the motion. The State did not specify exactly which portions of the social media records it intended to introduce but highlighted a particular group message as significant evidence of gang association. The trial court ruled orally and in a subsequent written order that only messages or posts authored by the defendant on trial, or those to which he directly responded, would be admissible; all other evidence of gang association from the social media records was excluded. The court’s reasoning focused on “basic fairness,” without citing specific evidentiary rules or legal standards.The Supreme Court of Georgia reviewed the case on the State’s appeal. The Court held that the trial court’s order must be vacated because it was unclear what legal standard the lower court applied in excluding the evidence. The Supreme Court found that the trial court did not clearly base its ruling on relevance or the balancing test required by OCGA § 24-4-403 (Rule 403), which governs the exclusion of relevant evidence if its probative value is substantially outweighed by unfair prejudice or other concerns. The Supreme Court vacated the order and remanded for further proceedings consistent with its opinion. View "THE STATE v. SIMS" on Justia Law

The case concerns the shooting death of Keshia Smith, who was killed on September 2, 2018. Demarko Marquez Moss was identified as the suspect after his father informed police that Moss may have been the shooter. Moss turned himself in the next day. Evidence at trial included testimony from Moss’s brother, who received a call from Moss shortly after the shooting, and text messages between Moss and Smith that suggested a tumultuous relationship. Smith was found dead in her car, with two young children in the back seat. The State also introduced evidence and expert testimony regarding domestic violence, though the expert had no specific knowledge of Moss or Smith.A Fulton County grand jury indicted Moss on multiple charges, including malice murder, felony murder, aggravated assault, and firearm offenses. At trial in the Superior Court of Fulton County, the jury acquitted Moss of two counts of cruelty to children but convicted him on the remaining charges. Moss was sentenced to life without parole plus additional consecutive sentences. He filed a motion for new trial, which was denied after an evidentiary hearing. Moss then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia affirmed Moss’s convictions. The court held that there was no plain error in failing to instruct the jury on confession corroboration because Moss’s statement to his brother was not a confession. The court found that Moss’s motion for a mistrial was not preserved for appellate review due to lack of a contemporaneous objection. Any error in admitting the domestic violence expert’s testimony was deemed harmless. The court also rejected Moss’s claims of ineffective assistance of counsel and found no cumulative error. View "MOSS v. THE STATE" on Justia Law

Owners of developed commercial and residential properties in Athens-Clarke County challenged the county’s stormwater utility charge, arguing that it was an unconstitutional tax rather than a fee. The charge, established by county ordinances in 2004, funds stormwater management services required by federal law, with the amount assessed based on impervious surface area and land-use classification. The ordinance exempts certain properties, such as public roads and sidewalks, and offers credits for on-site stormwater management. The funds collected are used for flood prevention, pollution minimization, and compliance with federal regulations.Previously, the Superior Court of Athens-Clarke County granted summary judgment to the county, finding that the stormwater utility charge was a fee, not a tax, and thus not subject to the Georgia Constitution’s taxation uniformity provision. This decision relied on the Georgia Supreme Court’s earlier ruling in Homewood Village, LLC v. Unified Government of Athens-Clarke County, which had addressed the same ordinance and held it imposed a fee rather than a tax. The appellants also pursued related claims in federal court, but those were dismissed on abstention grounds.On appeal, the Supreme Court of Georgia affirmed the trial court’s decision. The court held that its prior decision in Homewood Village, LLC v. Unified Government of Athens-Clarke County controlled, reaffirming that the stormwater utility charge is a fee and not a tax, and therefore the uniformity provision does not apply. The court also rejected the appellants’ arguments that the charge constituted an unconstitutional taking under the Georgia and United States Constitutions, finding no basis for such a claim. Finally, the court found that the trial court had properly applied the summary judgment standard and had not improperly resolved factual disputes. The judgment in favor of the county was affirmed. View "HOMEWOOD ASSOCIATES INC. v. UNIFIED GOVERNMENT OF ATHENS-CLARKE COUNTY" on Justia Law

In this case, the defendant was convicted in 2003 of felony murder and aggravated battery following the death of his two-month-old son, based on a diagnosis of Shaken Baby Syndrome (SBS). At trial, the prosecution relied on the then-prevailing medical consensus that a specific triad of symptoms in infants was diagnostic of SBS and indicative of abuse. Years later, the defendant sought a new trial, arguing that significant developments in medical science had undermined the reliability of the SBS diagnosis, and presented new expert testimony suggesting alternative, non-abusive causes for his son’s injuries and death.After the original conviction was affirmed on direct appeal, the defendant filed an extraordinary motion for new trial in the Superior Court of the county of conviction, citing newly discovered evidence in the form of updated expert analysis and medical literature. The trial court initially denied the motion without a hearing, but the Supreme Court of Georgia vacated that decision and remanded for an evidentiary hearing. On remand, after hearing extensive expert testimony from both sides, the trial court again denied the motion, finding that the evidence was not newly discovered, that the defendant had not exercised due diligence, and that the evidence was not material.The Supreme Court of Georgia reviewed the trial court’s decision and held that the trial court failed to apply the correct legal framework in evaluating the extraordinary motion for new trial. Specifically, the Supreme Court found that the trial court erred in its analysis of whether the evidence was newly discovered, whether the defendant exercised due diligence, and whether the new evidence was material. The Supreme Court vacated the trial court’s order and remanded the case for reconsideration under the proper legal standards. View "SMITH v. THE STATE" on Justia Law

Christopher Profet was charged with malice murder, armed robbery, and related offenses following the shooting death of Latonya Morris-Figg in Fulton County, Georgia. On May 15, 2014, Profet was seen with Morris-Figg as she cashed money orders intended for the purchase of a car. Surveillance footage placed them together at two stores, and Morris-Figg’s body was later found in a rural area, missing her purse, phone, and cash. Evidence at trial included witness testimony about Profet’s clothing and possession of a handgun, shoe impression analysis, and DNA evidence linking Profet to Morris-Figg. Profet’s statements to investigators were inconsistent with the timeline established by surveillance footage and witness accounts.After a jury trial in the Superior Court of Fulton County, Profet was convicted on all counts. He was sentenced to life in prison for malice murder, with additional concurrent and consecutive sentences for armed robbery and possession of a firearm during the commission of a felony. Profet’s motion for a new trial was denied, and after procedural delays regarding notice of the denial, he timely appealed.The Supreme Court of Georgia reviewed Profet’s claims, including sufficiency of the evidence, alleged errors regarding his right to testify, limitations on his defense, admission of expert testimony about shoe impressions, and the jury’s viewing of photographic evidence. The Court held that the evidence was sufficient to support the convictions, that the trial court was not required to secure an on-the-record waiver of Profet’s right to testify, and that no plain error occurred in admitting expert testimony under the applicable evidentiary standard. The Court also found no error in allowing the jury to view photographs during deliberations and rejected Profet’s claim of cumulative error. The Supreme Court of Georgia affirmed the convictions and sentences. View "PROFET v. THE STATE" on Justia Law

Daniel Cook, an independent contractor, was injured when he fell from an exposed, unguarded ledge while installing cabinetry in a second-story bathroom at a residential construction site owned by SMG Construction Services. Cook had previously observed the absence of a guardrail on the ledge and acknowledged this hazard in his deposition. At the time of the accident, he was moving backward toward the ledge while working. Cook sued SMG, alleging that the company failed to maintain a safe premises, which led to his injuries.The Superior Court granted summary judgment to SMG, finding that Cook had actual knowledge of the hazard and failed to exercise ordinary care for his own safety. The court concluded that Cook’s knowledge of the exposed ledge was equal to SMG’s, and therefore, SMG owed him no duty to warn or protect against the risk. On appeal, the Court of Appeals of Georgia reversed, holding that although Cook knew of the ledge, there was evidence that conditions at the site affected his ability to perceive the exact location and risk posed by the ledge. The appellate court found a genuine issue of material fact as to whether Cook’s knowledge of the hazard was equal to or greater than SMG’s.The Supreme Court of Georgia reviewed the case and determined that the Court of Appeals had conflated actual and constructive knowledge, erroneously applying standards relevant to constructive knowledge. The Supreme Court held that Cook’s own testimony established his actual knowledge of the specific hazard—the unguarded ledge—that caused his injury. The Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings to address the remaining elements of SMG’s affirmative defenses in light of Cook’s actual knowledge of the hazard. View "SMG CONSTRUCTION SERVICES, LLC v. COOK" on Justia Law

The plaintiff in this case alleged that she developed uterine fibroids as a result of using chemical hair relaxer products manufactured by two companies over a period spanning from 1995 to 2014. She purchased and used different products from each manufacturer at various times, applying them every six to eight weeks, with a brief pause between 2001 and 2002. She was diagnosed with uterine fibroids in 2018 and filed suit in 2022, claiming that the products contained harmful chemicals that caused her injury.The Superior Court denied the manufacturers’ motions to dismiss her strict products liability claims, which were based on Georgia’s ten-year statute of repose for such actions. The manufacturers argued that the statute of repose began running from the date the plaintiff first purchased any product from each manufacturer, which would bar her claims. On interlocutory appeal, the Court of Appeals of Georgia reversed, holding that the statute of repose for all units sold by each manufacturer to the plaintiff began with the earliest sale to her, and thus her claims were time-barred.The Supreme Court of Georgia reviewed the case to determine how the statute of repose under OCGA § 51-1-11(b)(2) applies when a plaintiff alleges injury from multiple consumable products sold over time. The Court held that the statute of repose applies on a per-unit basis, meaning the ten-year period begins with the sale of each individual unit as new to the end user. Therefore, claims are not barred for units sold within ten years of the lawsuit, even if earlier units were sold outside that period. The Court reversed the Court of Appeals’ decision in part and remanded the case, allowing the strict liability claims to proceed for units sold within the statutory period. View "BURROUGHS v. STRENGTH OF NATURE GLOBAL, LLC" on Justia Law