Justia Georgia Supreme Court Opinion Summaries

John McKnight filed a lawsuit against Anthony Love seeking damages from a vehicular accident. On November 13, 2019, both parties were driving on I-20 in DeKalb County when traffic slowed, and McKnight stopped his vehicle. Love, driving behind McKnight, failed to stop in time and collided with McKnight's vehicle. McKnight sustained injuries and his truck was damaged. Love was cited for following too closely and pleaded guilty to the offense. McKnight sought compensatory and punitive damages, as well as litigation expenses under OCGA § 13-6-11, alleging that Love acted in bad faith by being distracted, possibly using his cell phone at the time of the accident.The trial court denied Love's motion for partial summary judgment on the claim for litigation expenses, finding sufficient evidence to create a jury question regarding bad faith. The evidence included Love's cell phone records and McKnight's testimony suggesting Love was distracted. The trial court also denied Love's motion for summary judgment on claims of negligence per se but granted it on claims for punitive damages and stubborn litigiousness. Love did not challenge the negligence per se rulings, and McKnight's appeal on punitive damages and stubborn litigiousness was rejected by the Court of Appeals.The Supreme Court of Georgia reviewed the case and determined that the Court of Appeals erred in its analysis. The Court held that mere violations of traffic laws do not constitute bad faith under OCGA § 13-6-11. Bad faith requires intentional wrongdoing or reckless disregard of known harmful consequences, which is more than mere negligence. The Court found insufficient evidence of bad faith to support a claim for litigation expenses and reversed the Court of Appeals' judgment affirming the trial court's denial of Love's motion for partial summary judgment on the issue of bad faith litigation expenses. View "LOVE v. MCKNIGHT" on Justia Law

Mikeal Callaway was charged with malice murder and other crimes after a shooting spree in his SUV that spanned five miles, four hours, and two counties (Fulton and DeKalb) on February 21-22, 2018. The spree involved four separate shootings, resulting in one death and multiple injuries. Callaway was identified by witnesses and evidence, including surveillance footage and forensic analysis. He was arrested after a high-speed chase and found with a 9mm handgun linked to the shootings.The DeKalb County jury convicted Callaway on all counts, including malice murder, felony murder, aggravated assault, possession of a firearm by a convicted felon, possession of a firearm during the commission of a felony, and fleeing a police officer. He was sentenced to life without parole for malice murder, with additional consecutive sentences for other charges. Callaway's motion for a new trial was denied by the trial court, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the case and affirmed Callaway's convictions. The court held that the evidence was sufficient to support the jury's verdicts, including the aggravated assault charges for the children in the backseat of the car and the venue for the McMillon shooting. The court also found that the evidence of the Fulton County crimes was properly admitted as intrinsic evidence, and there was no prosecutorial misconduct that warranted reversal. Additionally, the court rejected Callaway's claims of ineffective assistance of counsel and found no cumulative error that denied him a fair trial. View "CALLAWAY v. THE STATE" on Justia Law

Terrance Hill was convicted of felony murder and other crimes related to the shooting death of Gloria Starr Armour. The incident occurred on July 25, 2016, during a shootout between Hill, his brother Devonte, and Joslyn McQueary, who were in one vehicle, and Keaira Dell and Demetrius Lukerson, who were in another vehicle. Armour, an innocent bystander in a third vehicle, was fatally struck by a projectile. Hill was indicted on multiple counts, including felony murder, aggravated assault, and possession of a firearm by a convicted felon. He was convicted on all counts and sentenced to life in prison without parole, plus additional consecutive sentences for other charges.Hill's motion for a new trial was denied by the trial court, leading to his appeal. He argued that the trial court committed plain error by not instructing the jury that a convicted felon could use a firearm in self-defense. He also claimed ineffective assistance of counsel for failing to secure a ruling on this instruction request. The trial court had given a general justification instruction but did not specifically address the use of a firearm by a convicted felon in self-defense.The Supreme Court of Georgia reviewed the case and found that while the trial court likely erred in not giving the specific instruction requested by Hill, this error was not clear and obvious under the plain-error standard. The court noted that existing precedents did not explicitly require such an instruction. Consequently, Hill's claim of plain error failed. Additionally, the court found that Hill's counsel did obtain an implicit ruling on the requested charge, and thus, there was no ineffective assistance of counsel. The Supreme Court of Georgia affirmed Hill's conviction. View "HILL v. THE STATE" on Justia Law

Savion Nathaniel Dillard was convicted in 2021 for malice murder and other crimes related to the armed robbery of two 15-year-olds, Branden Gerena and Denzel Idris, during which Gerena was fatally shot. Dillard had arranged to meet Gerena under the pretense of buying marijuana but instead robbed and shot him. Dillard fled the scene and was later apprehended in Wisconsin. Evidence included witness testimonies, security footage, and Dillard's own admissions.A Gwinnett County grand jury indicted Dillard and Denzel Wilburn, who later pled guilty to a reduced charge and testified against Dillard. The jury found Dillard guilty of all charges, and the trial court sentenced him to life in prison without parole for malice murder, with additional concurrent and consecutive sentences for other charges. Dillard's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case and affirmed the convictions. The court held that the evidence was sufficient to support the convictions under both constitutional due process and Georgia statutory law. The court found that the direct evidence, including testimonies from Idris and Antonio English, who testified about Dillard's admission, was sufficient. The court also rejected Dillard's argument that Idris's testimony required corroboration, as Idris was not an accomplice in the charged crimes but rather a victim. The court concluded that the evidence presented at trial was adequate to uphold Dillard's convictions. View "DILLARD v. THE STATE" on Justia Law

James Damon Clements was convicted of felony murder for the beating death of Shannon Goetz and sentenced for the aggravated assault of Gregg Olson. The crimes occurred on December 22, 2017. A Cherokee County grand jury indicted Clements on six counts, including malice murder, felony murder, aggravated battery, and aggravated assault. The jury found Clements not guilty of malice murder but guilty on the remaining counts, except for one count where he was found guilty of a lesser charge. He was sentenced to life in prison for felony murder and additional concurrent sentences for other charges.Clements filed a motion for a new trial, which was amended through new counsel. The trial court modified his sentence for aggravated assault from 25 years to 20 years but denied the motion in all other respects. Clements appealed, arguing that the evidence was insufficient to support his felony murder conviction and that his initial sentence for aggravated assault exceeded the statutory maximum.The Supreme Court of Georgia reviewed the case. Clements contended that the State failed to exclude the reasonable hypothesis that Goetz's death was caused by her methamphetamine use rather than her injuries. The court found that the jury was authorized to credit the testimony of Dr. James Upshaw Downs, who concluded that Goetz's death was a homicide and not caused by methamphetamine. The court held that the evidence was sufficient to support the conviction for felony murder.Regarding the sentence for aggravated assault, the court noted that the trial court had already modified the sentence to 20 years, which is within the statutory range. Therefore, the sentence was not void. The Supreme Court of Georgia affirmed Clements' conviction for felony murder and his 20-year sentence for aggravated assault. View "CLEMENTS v. THE STATE" on Justia Law

Evelyn-Natasha La Anyane was convicted of driving under the influence (DUI) of alcohol less safe and other traffic offenses. During a traffic stop, she was read the statutory implied-consent warning and consented to a blood test, which revealed a blood alcohol content above the legal limit. La Anyane argued that Georgia’s implied-consent statutory scheme is unconstitutional, claiming it coerces drivers into consenting to blood tests by falsely stating that refusal can be used against them at trial. She also contended that the trial court made evidentiary errors by not allowing her to cross-examine an expert with a study on field sobriety tests and by admitting evidence of her blood alcohol content.The trial court denied La Anyane’s motion to suppress the blood test results and admitted the evidence at trial. The jury found her guilty of all charges. La Anyane appealed, arguing that the implied-consent warning was unconstitutionally coercive and that the trial court made evidentiary errors.The Supreme Court of Georgia reviewed the case and held that the implied-consent warning was not unconstitutionally coercive. The court found that the warning did not state that consent was mandatory and that the statement about refusal being used at trial was not false. The court also determined that La Anyane’s consent to the blood test was freely and voluntarily given, making the search valid under the Fourth Amendment. Consequently, her as-applied and facial challenges to the implied-consent statutory scheme failed.Regarding the evidentiary issues, the court held that the trial court did not abuse its discretion in excluding the study on field sobriety tests due to lack of proper foundation and in admitting evidence of La Anyane’s blood alcohol content, as it was relevant to the DUI less safe charge and not unfairly prejudicial. The Supreme Court of Georgia affirmed the trial court’s judgment. View "LA ANYANE v. THE STATE" on Justia Law

Charvez Ryals was convicted of malice murder and other crimes related to the beating and fatal shooting of Daniel Wise. The incident occurred on March 10, 2018, in DeKalb County, Georgia. Ryals and his girlfriend, Regina Welch, had a history of domestic violence involving Wise, who was Regina's ex-boyfriend and the father of her three children. On the night before the murder, Wise confronted Regina and Ryals, demanding money and threatening them. The next morning, Wise returned to Regina's apartment, leading to a confrontation where Ryals shot Wise multiple times, resulting in his death.The case was initially tried in the Superior Court of DeKalb County, where a jury found Ryals guilty on all counts, including malice murder, felony murder, aggravated assault, cruelty to children, and firearm possession. The trial court sentenced Ryals to life in prison for malice murder, along with additional concurrent and consecutive sentences for the other charges. Ryals filed a motion for a new trial, which was denied by the trial court in March 2024.The Supreme Court of Georgia reviewed the case, focusing on Ryals' claims of ineffective assistance of counsel. Ryals argued that his trial counsel failed to subpoena a key witness, obtain phone records, introduce the criminal histories of Wise and another victim, and request a jury charge on voluntary manslaughter. The court found that these claims did not demonstrate deficient performance or resulting prejudice. The court held that the decisions made by Ryals' counsel were reasonable and strategic, and that any potential deficiencies did not affect the outcome of the trial. Consequently, the Supreme Court of Georgia affirmed the lower court's judgment, upholding Ryals' convictions and sentences. View "RYALS v. THE STATE" on Justia Law

James Christopher Jones was charged with murder after police identified her using cell phone location history obtained through search warrants. The warrants allowed police to get an anonymized list of devices near the victim’s home during the murder and identifying information for relevant devices. Jones moved to suppress this evidence, arguing the warrants violated the Fourth Amendment due to lack of probable cause and particularity. The trial court denied the motion, and Jones appealed.The trial court found the warrants were supported by probable cause and were sufficiently particular. The first warrant was based on evidence that the suspect used a cell phone near the victim’s home, and the second warrant, obtained after analyzing the anonymized data, identified a specific device linked to the suspect. The court concluded that the affidavits provided a fair probability that the location data and identifying information would yield evidence of the crime. The court also found the warrants were particular enough, specifying the crime, date, time, location, and a reasonable 100-meter radius.The Supreme Court of Georgia affirmed the trial court’s decision. The court held that the warrants were supported by probable cause, as the suspect was seen using a cell phone near the crime scene, and the location data was likely to help identify the suspect. The court also found the warrants met the particularity requirement, as they provided specific guidance on the information to be accessed and avoided unfettered discretion. The court rejected Jones’s arguments about overbreadth and lack of particularity, noting that the warrants were appropriately tailored to the investigation and did not authorize a general search. The judgment was affirmed. View "JONES v. THE STATE" on Justia Law

In 2020, Georgia ratified an amendment to its Constitution waiving sovereign immunity for actions seeking declaratory relief from unlawful acts by the State or local governments. This amendment included a procedural requirement that such actions must be brought against and in the name of only the State or the relevant local government, or they would be dismissed. The case at hand questions whether a complaint that does not comply with this naming requirement can be cured by dropping or adding parties to avoid dismissal.Warbler Investments, LLC sued the City of Social Circle, its mayor, and three City Council members in their individual capacities, alleging unlawful rezoning of Warbler's property and violations of the Open Records Act. The defendants moved to dismiss the claims, arguing that the complaint violated the naming requirement of the Georgia Constitution. Warbler then moved to amend the complaint to drop the individual defendants, which the trial court allowed. However, after the Georgia Supreme Court's decision in State v. SASS Group, LLC, which mandated dismissal of cases not complying with the naming requirement, the City renewed its motion to dismiss. The trial court granted the motion, dismissing the case despite the amendment.The Supreme Court of Georgia reviewed the case and concluded that the procedural defect of not complying with the naming requirement could be cured by amending the complaint to drop or add parties. The court held that the waiver of sovereign immunity was not affected by the initial failure to comply with the naming requirement, and the amended complaint, which complied with the requirement, should not be dismissed. The judgment was reversed, and the case was remanded. View "WARBLER INVESTMENTS, LLC v. CITY OF SOCIAL CIRCLE" on Justia Law

Yathomas Riley was convicted of malice murder and other crimes related to the shooting death of his wife, Dr. Lisa Marie Riley, in the presence of their infant son. The crimes occurred on June 14 and July 9, 2015. Riley was indicted on multiple counts, including malice murder, felony murder, and aggravated assault. After a jury trial, Riley was found guilty on all counts and sentenced to life in prison without parole, along with additional consecutive and concurrent prison terms for other charges.Riley filed a motion for a new trial, which was denied by the trial court. He then appealed to the Court of Appeals, which transferred the case to the Supreme Court of Georgia. The Supreme Court remanded the case to the trial court to determine if Riley knowingly and voluntarily chose to represent himself on appeal. The trial court confirmed this, and the case was resubmitted to the Supreme Court.The Supreme Court of Georgia reviewed Riley's claims, including the trial court's decision to allow the lead investigator to remain in the courtroom, the presentation of allegedly false evidence, and claims of ineffective assistance of counsel. The court found no abuse of discretion in allowing the investigator to stay, as he was the State's chief investigative agent. Riley's claims about false evidence and perjured testimony were either not preserved for appeal or lacked supporting evidence. The court also found that Riley failed to demonstrate that his trial counsel's performance was deficient or that any alleged deficiencies prejudiced his defense.Riley's claim that his trial counsel conceded guilt in violation of McCoy v. Louisiana was also rejected. The court concluded that counsel did not concede guilt but rather argued alternative theories to support acquittal, which did not violate Riley's Sixth Amendment rights. The Supreme Court of Georgia affirmed Riley's convictions and sentences. View "RILEY v. THE STATE" on Justia Law