Justia Georgia Supreme Court Opinion Summaries

Joshua Moulder was convicted of malice murder, armed robbery, and possession of a firearm during the commission of a felony in connection with the July 2006 shooting death of Anthony Rudolph and was also convicted of influencing a witness in 2014. He appealed, arguing the evidence was not sufficient to support his convictions related to the 2006 shooting and that counsel provided ineffective assistance by: not arguing that the State failed to prove the statute of limitation tolling provision alleged for the non-murder crimes committed in 2006; failing to raise a hearsay and Confrontation Clause objection to certain testimony given by the lead detective; failing to correctly advise Moulder about whether his prior convictions could be used to impeach him if he testified; inaccurately describing the reasonable-doubt standard in closing argument; and failing to object to a jury charge about statements made during formal court proceedings. Because the evidence was sufficient to support Moulder’s convictions and he has failed to prove his claims of ineffective assistance of counsel, the Georgia Supreme Court affirmed. View "Moulder v. Georgia" on Justia Law

Perry Lee Hatcher, Jr., was convicted by jury of felony murder and cruelty to children in the third degree in connection with the shooting death of his wife, Dashea Hatcher, in the presence of their son, M. H. Hatcher contended his attorney was ineffective for failing to object to the qualifications of the State’s expert witness and to rebut the expert’s opinion concerning fibers found on the murder weapon. Because Hatcher failed to carry his burden of showing ineffective assistance of counsel, The Georgia Supreme Court affirmed the trial court’s order denying his motion for a new trial. View "Hatcher v. Georgia" on Justia Law

After adjudicating A. H. delinquent, but finding that he was not in need of treatment, rehabilitation, or supervision, the juvenile court in this case entered an order dismissing the delinquency proceedings under OCGA § 15-11-600 (d) and sealing the record under OCGA § 15-11-701. The State appealed the juvenile court’s decision to seal the record, but the Court of Appeals dismissed the appeal, concluding that neither OCGA § 5-7-1(a)(1) nor OCGA § 5-7-1(a)(6) authorized the State to appeal the juvenile court’s order. The Georgia Supreme Court granted certiorari to determine whether “the Court of Appeals err[ed] in concluding that the State was not permitted to appeal under OCGA § 5-7-1(a).” The Supreme Court found with respect to subsection (a)(6), the issue was neither fully litigated below nor briefed by the parties in significant depth to the Supreme Court. "Thus, although this issue is properly before us in a narrow sense, it is not presented in a form that would allow us to clarify the law or otherwise provide meaningful guidance." Accordingly, the writ was vacated, and the petition for certiorari in Case No. S22C1035 was denied. View "In the Interest of A.H." on Justia Law

This appeal arises from a fatal collision between a tractor-trailer driven by Lloy White and a car driven by Kristie Miller. The issue it presented for the Georgia Supreme Court's review centered on whether the well-established test governing the admissibility of expert testimony applied with equal force to investigating law enforcement officers. To this, the Court held that when an investigating law enforcement officer provides expert testimony, the officer is subject to the same inquiry as all witnesses who offer expert opinion testimony and, therefore, the trial court abused its discretion in failing to conduct a full, three-prong analysis under Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), and its progeny. View "Miller, et al. v. Golden Peanut Company, LLC, et al." on Justia Law

The Hearing Panel of the Georgia Judicial Qualifications Commission (JQC) recommended that Gerald Johnson be removed from office for violating Rules 1.1, 1.2 (A), and 1.2 (B) of the Georgia Code of Judicial Conduct (“CJC”). Johnson, however, submitted his resignation to Governor Kemp shortly after the Hearing Panel filed its Report and Recommendation. Removal from office was the only sanction the JQC seeks, and the Georgia Supreme Court could not remove a former judge from an office he no longer holds. Accordingly, this matter was dismissed. View "Inquiry concerning Judge Gerald Johnson" on Justia Law

Georgia Court of Appeals Judge Christian Coomer was charged with patterns of behavior regarding his use of campaign funds and his dealings with a legal client that allegedly undermined public confidence. The Hearing Panel of the Judicial Qualifications Commission (“JQC”) found that he indeed committed those acts, that he did so in bad faith, that those acts violated the Georgia Code of Judicial Conduct, and that the violations warranted his removal. The Georgia Supreme Court found that enough of the Hearing Panel’s findings were supported by sufficient evidence that, notwithstanding alternative ways that the evidence could have been viewed, the Court deferred to the Hearing Panel’s findings regarding Judge Coomer’s actions and the bad faith in which the Hearing Panel found those actions to have been taken. The Court concluded the appropriate sanction was to remove Judge Coomer from the bench. View "Inquiry concerning Judge Christian Coomer" on Justia Law

Appellant Bobby Wood, Jr. was convicted of felony murder in connection with the 2020 shooting death of Aaron Skinner. On appeal, Appellant contended: (1) the trial court abused its discretion in denying him the opportunity to cross-examine the State’s expert witness about Skinner’s alleged arrest for criminal trespass on the day before the shooting; (2) the trial court violated his right to due process by denying him access to certain physical evidence post-trial; (3) trial counsel was ineffective for failing to object to the State’s redirect examination of the State’s expert witness as outside the scope of redirect examination; and (4) the cumulative effect of the alleged errors committed by the trial court and trial counsel deprived Appellant of a fair trial. Finding no reversible error, the Georgia Supreme Court affirmed. View "Wood v. Georgia" on Justia Law

Sean Allen appealed his conviction for felony murder for the 2021 shooting death of Daquan Gillett. Allen argued: (1) the trial court erred when it failed to grant him immunity from prosecution based on self-defense; (2) the evidence presented at trial was insufficient to support his conviction; (3) the trial court erred by limiting his ability to argue the law of self-defense in closing argument; and (4) trial counsel was ineffective in several respects. Finding no reversible error, the Georgia Supreme Court affirmed. View "Allen v. Georgia" on Justia Law

Patrick Middleton moved to suppress evidence obtained during a search by Officer Amanda Graw of the Kingsland Police Department (“KPD”), arguing that she did not have authority to stop or search him because she was outside the territorial jurisdiction of the KPD. Officer Graw claimed that she did have authority to perform the stop and search because she had been deputized by the Camden County Sheriff’s Office (“CCSO”) seven years earlier. After the trial court granted the motion to suppress, the State appealed. The Court of Appeals reversed, concluding that Officer Graw had presented sufficient evidence of her deputization. After its review, the Georgia Supreme Court vacated the Court of Appeals’ opinion with direction that it vacate the trial court’s order and remand the case to the trial court with direction to clarify its basis for ruling that the search and seizure of Middleton was unlawful. View "Middleton v. Georgia" on Justia Law

In 2009, a jury convicted David Edenfield for the 2007 sexual assault and murder of six-year-old Christopher Barrios, and the jury imposed a death sentence for the murder. Lead trial counsel, joined by other attorneys, represented Edenfield on direct appeal, and, in June of 2013, the Georgia Supreme Court affirmed Edenfield’s convictions and sentences on direct appeal. Edenfield subsequently filed a petition for a writ of habeas corpus, asserting he was ineligible for the death penalty because he is intellectually disabled and that trial counsel provided constitutionally ineffective assistance during his trial in several ways, including by failing to present evidence of Edenfield’s alleged intellectual disability in the sentencing phase as mitigating evidence. He also contended that appellate counsel had provided ineffective assistance. The habeas court denied relief on all claims except for the ineffective assistance of trial counsel claim concerning counsel’s presentation of evidence of Edenfield’s alleged intellectual disability as mitigating evidence in the sentencing phase. Based on that claim, the habeas court vacated Edenfield’s death sentence. The Warden appealed in Case No. S23A0260, and Edenfield has cross-appealed in Case No. S23X0261. In the Warden’s appeal, the Georgia Supreme Court reversed the habeas court’s decision to vacate Edenfield’s death sentence. In Edenfield’s cross-appeal, the Court affirmed in part; the Court conclude as to Edenfield’s claim regarding trial counsel’s alleged deficiency concerning certain allegedly mitigating circumstances that additional findings of fact and conclusions of law were required, and the case was therefore remanded to the habeas court for further proceedings. View "Caldwell v. Edenfield" on Justia Law