Justia Georgia Supreme Court Opinion Summaries

Following the suicide death of her 14-year-old daughter, Appellee Laura Lane Maia sued the mayor and city council of the City of Richmond Hill (collectively, “the City”) and Douglas Sahlberg, individually and in his capacity as an officer with the Richmond Hill Police Department (collectively “Appellants”), alleging wrongful death and associated claims. Appellee’s daughter, Sydney Sanders, attempted suicide by cutting herself in the neck, chest, and abdomen, and she was subsequently taken to the hospital for medical treatment. Officers with the Richmond Hill Police Department (“RHPD”), including Officer Sahlberg, responded to the hospital to investigate, and Sanders’s injuries were photographed by the officers. Sahlberg accessed those photographs on his work computer and showed them to his daughter, K.S., who was a classmate of Sanders; shortly thereafter, K.S. was seen using her cell phone to show the images to other classmates. Sanders was distraught and mortified to discover that the photographs had been shared. In her complaint, Appellee averred (inter alia): that Salhberg had a duty to keep the injury photographs confidential; that he had breached that duty; that Sahlberg should have known that the publication of the photographs created a reasonable apprehension that Sanders would further harm herself; and that Sanders’s death was caused by Sahlberg’s negligent conduct. Appellants moved for summary judgment, asserting that Appellee could not demonstrate causation because, under Georgia law, suicide was generally an independent act which breaks the chain of causation from the events preceding the death. The trial court denied the motion with a one-page order and granted a certificate of immediate review. A divided Court of Appeals affirmed, concluding that, because “Sanders’s suicide was a reasonably foreseeable consequence of Sahlberg’s negligent conduct, [Sanders’s] act of suicide was not an intervening act that would preclude Sahlberg’s breach of duty from constituting the proximate cause of that injury.” The Supreme Court concluded Appellee could not demonstrate proximate cause and therefore reversed the Court of Appeals. View "City of Richmond Hill v. Maia" on Justia Law

This case made a second appearance before the Georgia Supreme Court. Jeffrey Sponsler (Husband) appealed the trial court’s order finding him in contempt of the final decree effectuating his divorce from April Sponsler (Wife). When the Supreme Court granted Husband’s application, it issued two questions for argument and consideration: (1) Did the trial court err by ordering both parties to share responsibility for home equity line of credit (HELOC) payments on the rental home until it is sold? (2) Did the trial court err by ordering Husband to repair the rental property? The Court found that although the trial court ultimately did not err in finding Husband to be in contempt of the divorce decree, the trial court did err by ordering Husband to share ongoing responsibility for HELOC payments and to make repairs to the rental property. View "Sponsler v. Sponsler" on Justia Law

In the course of representing criminal defendants in two cases, an attorney at the Merchant Law Firm participated in three hearings before Judge David Emerson in June and October 2015. Each of these proceedings was open to the public and audio-recorded by court reporter Melissa Cantrell, who subsequently transcribed the hearings. The Firm emailed Cantrell, requesting copies of the audio recordings of the three hearings. Cantrell responded, stating that she had consulted with Judge Emerson, who advised that the Firm should file a motion in order to make a formal request for the recordings. Later that day, the Firm emailed Cantrell (copied to Judge Emerson) that “no such motion is needed, and any instruction that these tapes be withheld until a motion is filed (and presumably ruled upon) is contrary to the Court’s rules and the long-established black letter law in Georgia regarding the public’s access to court records.” When such a motion was ultimately made, the Judge denied it, and the Firm petitioned the Georgia Supreme Court for mandamus relief, arguing: (1) the right of access to court records, as provided by Uniform Superior Court Rules 21 through 21.6 (“Rule 21”), included the right to make copies of the recordings; (2) the Firm lacked an adequate legal remedy to vindicate that right; and (3) public officials violated their public duties by refusing to allow the Firm to make copies. The Supreme Court found Rule 21 indeed provided an adequate remedy at law, thus the Court affirmed dismissal of the Firm’s mandamus and injunctive claims. The Court also affirmed dismissal of the Firm’s claim for declaratory judgment, because such a claim cannot be used as a collateral attack on Judge Emerson’s order. View "Merchant Law Firm, P.C. v. Emerson" on Justia Law

The Georgia Supreme Court found no reversible after certiorari review of appellant Edward Clements, Jr.’s appeal. Appellant was convicted of the malice murder, felony murder, conspiracy to commit murder, and various other offenses in connection with a murder-for-hire plot that ended with the shooting death of his wife, Joni. On appeal, appellant challenged the sufficiency of the evidence presented against him at trial. Finding the evidence sufficient to support the verdict, the Supreme Court affirmed. View "Clements v. Georgia" on Justia Law

Samuel Steplight appealed his convictions and sentences for felony murder, possession of a knife during the commission of a crime, and terroristic threats, all in connection with the 2010 death of Norma Jean Mobley. Steplight contends that the evidence was insufficient to authorize the jury to find him guilty beyond a reasonable doubt of the crime of terroristic threats. The Georgia Supreme Court agreed, after review, the evidence did not support an inference that Steplight intended or expected his statements to be communicated to Mobley, and there was no evidence to support the inference that he intended or expected that they would be. The Court therefore reversed on that charge. Finding no other reversible error, the Supreme Court reversed in part, affirmed in part, and remanded for further proceedings. View "Steplight v. Georgia" on Justia Law

The Georgia Supreme Court found no reversible after certiorari review of appellant Benjamin Johnson’s appeal. Appellant was convicted of the 2013 murder of his brother Timothy. The trial court denied Johnson’s amended motion for a new trial, and he appealed, arguing the trial court erred in admitting hearsay testimony of a prior altercation between the brothers. He also argued he received ineffective assistance of counsel for failing to object to the admission of that testimony or for not investigating the prior altercation. The Supreme Court found that admission of the hearsay testimony was harmless error in light of the substantial evidence of appellant’s guilt and the limited pertinence of the testimony. Further, the Court determined that trial counsel’s failure to object to the testimony would not have affected the outcome of trial. View "Johnson v. Georgia" on Justia Law

The Georgia Supreme Court concluded the State failed to provide a meritorious basis for reversal of the superior court’s grant of Olubumi Ogunsuyi’s motion for immunity from prosecution. Ogunsuyi was indicted for malice murder and related crimes in connection with the January 22, 2015 fatal shooting of Courtney Daniels, Sr. The State appealed a superior court order granting Ogunsuyi’s pretrial motion for immunity from prosecution pursuant to OCGA § 16-3-24.2 based on her claim that the shooting was in self-defense. Specifically, the State complained that the superior court’s determination that Ogunsuyi was credible was based, in part, on a document which was filed of record but not admitted at the pretrial hearing. The Supreme Court agreed that it was error for the superior court to cite the subject discovery disclosures by the State as support for its findings. The State argued the corroboration evidence relied on by the superior court could have come only from information contained in those disclosures, not introduced at the motion hearing. The Supreme Court concluded that contention was simply not true. All of the information the court mentions as proving Ogunsuyi’s credibility came most clearly from evidence at the hearing. To the extent this evidence was echoed by the disclosures, they did not serve to clarify or further corroborate any material evidence. “There simply is no showing of harm.” View "Georgia v. Ogunsuyi" on Justia Law

The Georgia Supreme Court found that appellant Avery Bryant’s trial counsel was ineffective for failing to challenge the sufficiency of the police warrant leading to Bryant’s arrest. The warrant in question did not adequately describe the items police intended to seize, therefore the search was presumptively unreasonable and unconstitutional, “the warrant here did not simply omit a few items from a list of many to be seized, or misdescribe a few of several items . . . , the warrant did not describe the items to be seized at all.” Bryant had been convicted by jury of malice murder, felony murder, aggravated assault with a deadly weapon, possession of a firearm during the commission of a felony, and possession of a pistol by a person under age 18. On appeal, he argued ineffective assistance of counsel, and that the trial court erred in instructing the jury. In light of the ineffective assistance claim, the Georgia Supreme Court did not address Bryant’s remaining claims of error, and remanded the case for further proceedings. View "Bryant v. Georgia" on Justia Law

The Georgia Supreme Court found no reversible after certiorari review of appellant Kemra Matthews’ appeal. Appellant was convicted of the felony murder of Jadien Harvey, and the aggravated assault of Ashton Capers. On appeal, appellant argued he received ineffective assistance of counsel, and challenged the sufficiency of the evidence presented against him at trial. View "Matthews v. Georgia" on Justia Law

The Georgia Supreme Court found no reversible after certiorari review of appellant William Speziali’s appeal. Appellant was convicted of the 2011 malice murder of Jimmy Breedlove and related crimes. On appeal, appellant argued he received ineffective assistance of counsel, and challenged the sufficiency of the evidence presented against him at trial. View "Speziali v. Georgia" on Justia Law