Justia Georgia Supreme Court Opinion Summaries

Chad Haufler was convicted by jury in 2021 of malice murder and other crimes in connection with the shooting death of Marc Dimos. On appeal, Haufler argued the trial court erred in failing to instruct the jury on involuntary manslaughter and in denying his pretrial motion to suppress certain statements he made in the presence of law enforcement officers. Finding no reversible error, the Georgia Supreme Court affirmed. View "Haufler v. Georgia" on Justia Law

Appellant Robert Gonzales challenged his convictions for aggravated battery and felony murder, predicated on cruelty to children in the first degree, in connection with the death of three-year-old Samuel Carroll, the son of Appellant’s girlfriend Jocelyn Carroll. Appellant contended the evidence was insufficient to support his convictions. After review, the Georgia Supreme Court concluded that the evidence presented at trial was legally sufficient to support Appellant’s convictions as a matter of constitutional due process. However, the Court vacated Appellant’s sentence for aggravated battery because this count should have merged with the felony murder conviction under these particular facts. View "Gonzales v. Georgia" on Justia Law

After Marina Middlebrooks pleaded not guilty by reason of insanity to charges arising from the stabbing death of her daughter, Sky Allen, a jury found Middlebrooks guilty of murder and cruelty to children in the first degree. On appeal, Middlebrooks contended that the trial court erred in allowing the State’s expert witness to testify as to what happens when a person is found not guilty by reason of insanity. In addition, Middlebrooks contended “[t]he trial court erred in restricting the testimony of [her] diagnosing psychiatrist,” an employee of the Department of Veterans’ Affairs (“VA”), “without following the correct procedure” under federal regulations concerning the testimony of VA personnel in legal proceedings. In a related claim, Middlebrooks contended her “trial counsel was ineffective in failing to object to the limitation of [the witness’s] testimony by the [f]ederal [g]overnment and the [p]rosecutor.” Finding no reversible error, the Georgia Supreme Court affirmed. View "Middlebrooks v. Georgia" on Justia Law

Appellant Jaquest Norris challenged his 2018 convictions for felony murder and cruelty to children in the first degree in connection with the beating death of a child, eight-month-old Monte Jones. Norris contended the evidence was legally insufficient to support his convictions. Appellant also contended his trial counsel provided constitutionally ineffective assistance by failing to impeach one of the State’s expert witnesses, Dr. Deborah Young, with evidence that Monte had two healed fractures in his left leg after Dr. Young testified that she recalled Monte having only recent fractures. Because the Georgia Supreme Court concluded the evidence was legally sufficient to sustain Appellant’s convictions, and because Appellant failed to show prejudice from any alleged deficiency in trial counsel’s actions, the convictions were affirmed. View "Norris v. Georgia" on Justia Law

Fred Charles appealed his convictions for malice murder and related offenses in connection with the July 2015 shooting death of Stephanie Daniel. Charles argued: (1) the trial evidence was insufficient to support his convictions; (2) the trial court failed to appropriately question jurors regarding a potential issue of juror irregularity; (3) the trial court erred in denying his pretrial motion to bifurcate the trial and try separately the charges for which his status as a felon was material; and (4) trial counsel was ineffective for failing to object to the State using a felon-in-possession-of-a-firearm charge as a predicate for felony murder. Finding no reversible error, the Georgia Supreme Court affirmed. View "Charles v. Georgia" on Justia Law

Jeremy Taylor was convicted by jury of the malice murder of Eric Bolar and the aggravated battery of Seaborn Roberts. Taylor raised five claims of error on appeal: that (1) the trial court abused its discretion by excluding evidence about Taylor’s mental health; (2) the trial court erred by sentencing Taylor based on an inference that Taylor did not accept responsibility or feel remorse for his crimes because he did not plead guilty; (3) the trial court abused its discretion by denying Taylor’s motion for a mistrial after a defense witness opined on the legal definition of aggravated battery; (4) Taylor received ineffective assistance of counsel because his lawyer did not investigate and present an insanity defense; and (5) Taylor received ineffective assistance of counsel because his lawyer failed to introduce mitigation evidence based on Taylor’s mental health. Finding no reversible error, the Georgia Supreme Court affirmed Taylor’s convictions and sentences. View "Taylor v. Georgia" on Justia Law

The State appealed the grant of defendant Roceam Wilson’s motion to suppress. Wilson was indicted for, among other things, murder in connection with the shooting death of Bradly Jordan. The State contended the trial court erred in concluding that the search warrant issued for Wilson’s cell phones was overbroad and authorized a general search in violation of the Fourth Amendment to the United States Constitution. In reviewing the trial court’s grant of the motion to suppress, “we apply the well-established principles that the trial court’s findings as to disputed facts will be upheld unless clearly erroneous and the trial court’s application of the law to undisputed facts is subject to de novo review.” Applying that standard here, the Georgia Supreme Court found no error in the trial court’s order. Accordingly, the order was affirmed. View "Georgia v. Wilson" on Justia Law

Appellant Jonathan Evans challenged his convictions for malice murder and other crimes in connection with the shooting death of Jamirus Wright and the non-fatal shooting of Brandon Martin. Appellant’s only claim on appeal was that he was denied constitutionally effective assistance of counsel at trial due to his attorney’s failure to introduce into evidence footage from the initial responding officers’ body cameras containing statements by them that he claimed would have lent support to his sole defense of justification. However, the Georgia Supreme Court found Appellant did not show that his trial counsel’s failure to introduce such evidence was objectively unreasonable. Thus, he failed to show that his counsel’s performance was constitutionally deficient, which was fatal to his claim. Accordingly, the Court affirmed his convictions. View "Evans v. Georgia" on Justia Law

In February 2014, a grand jury indicted Logan Bowman for crimes against his daughter. At the next term of court, Bowman properly invoked his right to a speedy trial pursuant to the Georgia speedy trial statute, OCGA § 17-7-170. More than five years later, the State still had not brought him to trial before 12 citizens sworn by the court or the court clerk to “well and truly try the issue formed upon this bill of indictment . . . and a true verdict give according to the evidence,” so Bowman moved for discharge and acquittal on speedy trial grounds, which the trial court granted. The State appealed, and in State v. Bowman, 361 Ga. App. 465 (863 SE2d 180) (2021), the Court of Appeals reversed, holding that a “trial” by an unsworn group of citizens satisfied the requirements of OCGA § 17-7-170. The Georgia Supreme Court granted Bowman’s petition for certiorari and reversed the Court of Appeals’ judgment. View "Bowman v. Georgia" on Justia Law

A resort community in North Georgia included a golf course next to a subdivision. The current owner of the resort wanted to redevelop the golf course into a residential property, and several homeowners in the subdivision sued to stop it. The trial court concluded that the homeowners had an easement in the golf course and granted a permanent injunction preventing the course from being put to any other use, and the Georgia Court of Appeals affirmed. The Georgia Supreme Court granted certiorari and vacated the Court of Appeals’ decision and remanded for further proceedings. Both courts below concluded that the homeowners acquired an easement in the golf course because their lots were bought with reference to a subdivision plat that designated a “golf course” next to the subdivision. The Supreme Court found that conclusion relied on a long line of decisions recognizing that easements in features like streets, parks, and lakes could be acquired on this basis, which amounted to an easement by express grant. But golf courses are different. Given the wide range of interests that an easement in a golf course could possibly include— interests in a view, access, use, or enjoyment, to name a few—merely designating a “golf course” on a subdivision plat and selling lots with reference to the plat "cannot give reasonable certainty as to the scope of a claimed easement." So, although subdivision owners might be able to acquire an easement in a given adjacent golf course, the intent to convey such an interest must be shown through evidence based in the relevant documents taken as a whole, rather than presumed based on the golf course’s mere designation on a plat. View "WS CE Resort Owner, LLC v. Holland, et al." on Justia Law