Justia Georgia Supreme Court Opinion Summaries

Appellant Dennaryl Head was convicted of felony murder and other crimes in connection with the 2006 shooting death of Dwight Smith. On appeal, Head contended that: (1) the evidence presented at trial was legally insufficient to sustain the verdict against him under former OCGA § 24-4-8; and (2) the trial court abused its discretion under former OCGA § 24-3-1 by admitting hearsay testimony from a police detective. The Georgia Supreme Court concluded that the evidence was sufficient under former OCGA § 24-4-8 because the testimony of Head’s accomplice was sufficiently corroborated. "And, pretermitting whether the trial court erred in admitting the challenged testimony," the Court concluded any error was harmless. View "Head v. Georgia" on Justia Law

Appellant Trevis Price was convicted by jury of malice murder and other offenses in connection with the deaths of L. C. Tumblin Jr. and Dexter Covin. On appeal, Price challenged the sufficiency of the evidence supporting his convictions for malice murder and the trial court’s denial of his motion to sever the charge for possession of cocaine with intent to distribute. Finding no reversible error in the trial court's judgment, the Georgia Supreme Court affirmed. View "Price v. Georgia" on Justia Law

In 2018, Mary Jackson and a nonprofit organization, Reaching Our Sisters Everywhere, Inc. (“ROSE”), filed a complaint against the Georgia Secretary of State challenging the constitutionality of the Georgia Lactation Consultant Practice Act (“the Act”), OCGA §§ 43-22A-1 to 43-22A-13. Under the Act, the Secretary issues licenses authorizing lactation care providers to provide lactation care and services for compensation. Only lactation care providers who obtain a privately issued certification as an International Board Certified Lactation Consultant (“IBCLC”) were eligible to obtain a license. Jackson and ROSE (collectively “Plaintiffs”) alleged their work included the provision of lactation care and services and that the Act was irrational and lacked any real and substantial connection to the public health, safety, or welfare because there was no evidence that non-IBCLC providers of lactation care and services ever harmed the public. They also contended the Act would require them to cease practicing their chosen profession, thus violating their rights to due process and equal protection under the Georgia Constitution. In the first round of this litigation, the trial court granted the Secretary’s motion to dismiss for failure to state a claim, but the Georgia Supreme Court reversed and remanded with direction. Following remand, the Secretary withdrew his motion to dismiss, and the parties engaged in discovery and filed cross-motions for summary judgment. On the due process claim, the trial court granted the Secretary’s motion for summary judgment, and on the equal protection claim, the trial court granted Plaintiffs’ motion. The Secretary appealed, and Plaintiffs filed a cross-appeal. The Supreme Court concluded in the cross-appeal that the Act was unconstitutional on due process grounds and that the trial court therefore erred in granting summary judgment to the Secretary and denying it to Plaintiffs. Accordingly, the Court reversed the trial court on the due process claim and did not reach the equal protection claim raised in the main appeal. View "Raffensperger v. Jackson, et al." on Justia Law

Appellant Elkin King sued Appellee Forrest King, Jr., his former stepfather, in federal district court, alleging that Forrest had concealed, misused, and converted the proceeds of a wrongful death settlement that had been placed in an account for Appellant’s benefit when Appellant was a minor, and Forrest was the custodian. Appellant further alleged that Forrest’s actions had allowed Appellant’s mother, Peggy Fulford, to spend the funds remaining in the account after Appellant turned 18 years old. The district court granted summary judgment in favor of Forrest. The United States Court of Appeals for the Eleventh Circuit affirmed summary judgment on the misuse claim and held that Appellant had forfeited his conversion claim. But as to the concealment claim, the Eleventh Circuit certified three questions to the Georgia Supreme Court, seeking clarification of the parameters of Georgia’s duty to disclose in a confidential relationship. The Supreme Court responded to the Eleventh Circuit’s certified questions: when a confidential relationship is also a fiduciary relationship, the fiduciary’s fraudulent breach of the duty to disclose can give rise to a breach-of-fiduciary-duty tort claim if that breach violates a fiduciary’s duty to act with the utmost good faith. "But whether a fiduciary has failed to act with the utmost good faith in a particular circumstance is a question of fact, not law." Accordingly, the Supreme Court answered the Eleventh Circuit’s first question and declined to answer the other two questions. View "King v. King" on Justia Law

In 2007, Jeremy Moody was charged with the rape and murder of 13-year-old Chrisondra Kimble and the murder of Kimble’s 15-year-old cousin, Delarlonva Mattox, Jr., and other related offenses. Shortly after Moody’s jury trial began in April 2013, Moody pleaded guilty to two counts each of malice murder, felony murder predicated on aggravated assault, aggravated assault, aggravated assault with intent to rob, and kidnapping with bodily injury, as well as to one count of rape. At the conclusion of the sentencing phase, a jury found the existence of multiple statutory aggravating circumstances as to each murder and recommended a sentence of death for each murder, and the trial court sentenced Moody accordingly. On appeal, Moody raised thirteen claims of error, each of which the Georgia Supreme Court rejected, affirming the convictions and sentence. View "Moody v. Georgia" on Justia Law

A habeas court granted relief to Jonathon Medina on the grounds that his guilty plea was involuntary and trial counsel was ineffective. Timothy Ward, the Commissioner of the Georgia Department of Corrections, appealed the habeas court’s order, challenging each of those grounds. Because the Georgia Supreme Court concluded the habeas court did not err in granting relief to Medina on his involuntary-plea claim, and affirmed the habeas court’s decision on that ground without addressing that court’s rulings on Medina’s ineffective assistance claims. View "Ward v. Medina" on Justia Law

Appellant Dwight Blalock, Jr., was convicted of malice murder and other crimes in connection with the 2014 fatal shooting of Carlos Wright and the aggravated assault of Bryan Morrow. On appeal, Blalock contended: (1) the trial court abused its discretion and denied Blalock due process by refusing to grant his motion for continuance; (2) Blalock’s trial counsel rendered ineffective assistance by failing to argue that the discovery statute, OCGA § 17-16-4, was unconstitutional as applied in this case; and (3) the trial court erred in permitting a State’s witness to comment on Blalock’s silence. Finding no reversible error, the Georgia Supreme Court affirmed Blalock’s convictions. View "Blalock v. Georgia" on Justia Law

In 2017, Erasmus Chandler was found guilty by jury of aggravated child molestation and two counts of child molestation. In 2019, the Court of Appeals affirmed his convictions in an unpublished opinion. Chandler later filed a pro se petition for habeas corpus, which the habeas court granted in 2022 on the ground that Chandler’s appellate counsel provided ineffective assistance at the motion for new trial stage and on appeal, including by failing to raise and prove claims of ineffective assistance of trial counsel. Warden Aimee Smith appealed, arguing that the habeas court erred in admitting an exhibit at the habeas hearing and in determining that Chandler’s appellate counsel provided ineffective assistance. The Georgia Supreme Court found the the warden did not object to the admission of the challenged exhibit for the limited purpose for which it was admitted, and on appeal the warden has not shown plain error in its admission. Moreover, the habeas court properly determined that Chandler’s appellate counsel provided ineffective assistance at the motion for new trial stage and on appeal by failing to raise and prove a claim of ineffective assistance of trial counsel for failing to impeach the alleged victim’s testimony at trial with evidence that she had made prior inconsistent statements about the alleged abuse. Accordingly, the Supreme Court affirmed the habeas court’s grant of relief on this basis. View "Smith v. Chandler" on Justia Law

Brandon Williams appealed his convictions for malice murder and possession of a firearm during the commission of a felony in connection with the shooting death of Corey Coleman. Williams contended the trial court erred: (1) when it did not allow him to show his left arm during the cross-examination of a detective; (2) when it allowed testimony about a deceased person’s out-of-court identification of Williams; (3) when it failed to charge the jury on self-defense; and (4) when it allowed introduction of Coleman’s statements to his mother. Williams also contended he received ineffective assistance of trial counsel. Finally, Williams argued the cumulative errors created sufficient prejudice that he must receive a new trial. Because Williams failed to show reversible error, the Georgia Supreme Court affirmed. View "Williams v. Georgia" on Justia Law

Appellants Michael Ward and Frederick Dewberry were convicted of malice murder and felony murder in connection with the stabbing death of Antonio Wiley and aggravated assault in connection with the stabbing of Wydreicus Denison. Ward contended: (1) the evidence was not sufficient to support his convictions; and (2) the trial court erred in denying his motion for a new trial. In his appeal, Dewberry contended the trial court erred by: (1) denying his motion for directed verdict of acquittal on the murder and aggravated assault charges; (2) allowing a “heavy police presence” in the courtroom in violation of his right to a fair trial; (3) leaving a defense witness in visible restraints; and (4) not declaring a mistrial after the prosecutor conferred with a witness, in violation of the rule of sequestration. Finding no reversible error in either appellant's contentions, the Georgia Supreme Court affirmed in both cases. View "Ward v. Georgia" on Justia Law