Justia Georgia Supreme Court Opinion Summaries

Jaylen Leverette was indicted along with three others for aggravated assault and felony murder related to a shooting incident on August 1, 2018, where a bystander was killed. Leverette filed a motion to suppress incriminating statements made during a custodial interview, arguing they were inadmissible under various legal grounds, including OCGA § 24-8-824, which excludes confessions induced by the slightest hope of benefit.The trial court granted Leverette’s motion to suppress, finding that his confession was induced by a hope of benefit. The court focused on statements made by Major Ralph Stuart during the interview, which suggested that Leverette would not be charged with the fatal shooting if he admitted his involvement. The court concluded that these statements constituted assurances that persuaded Leverette to confess.The Supreme Court of Georgia reviewed the case and concluded that the trial court erred in its decision. The court held that the statements made by Major Stuart did not constitute an impermissible hope of benefit under OCGA § 24-8-824. The court explained that the comments made by Stuart were not promises related to reduced criminal punishment but rather exhortations to tell the truth. The court emphasized that statements indicating that telling the truth would be beneficial or that lying would make things worse do not violate the statute.As a result, the Supreme Court of Georgia vacated the trial court’s order suppressing Leverette’s statements and remanded the case for further proceedings to consider Leverette’s other grounds for excluding his statements. View "THE STATE v. LEVERETTE" on Justia Law

A woman who had been in a long-term romantic relationship with a child's legal mother sought joint legal custody and parenting time under Georgia's Equitable Caregiver Statute, OCGA § 19-7-3.1, after the couple broke up. The statute allows a non-parent to seek custody or visitation rights if they have undertaken a parental role and developed a bonded and dependent relationship with the child, supported by a parent. The child's mother challenged the constitutionality of the statute and the sufficiency of the evidence supporting the trial court's order.The Superior Court granted the woman's request for equitable caregiver status, finding that she had established a bonded and dependent relationship with the child and that the child would suffer long-term emotional harm without continued contact. The court awarded joint legal custody and parenting time to the woman, despite the mother's objections.The Supreme Court of Georgia reviewed the case and raised concerns about the constitutionality of the Equitable Caregiver Statute, particularly regarding the fundamental right of parents to the care, custody, and control of their children. The court noted that any waiver of this constitutional right must be knowing and voluntary, and that conduct prior to the statute's effective date could not constitute such a waiver. The court concluded that the statute does not authorize trial courts to confer equitable caregiver status based on conduct by the legal parent that took place before the statute's effective date.The Supreme Court of Georgia reversed the trial court's order, holding that the Equitable Caregiver Statute does not apply to parental conduct occurring before its effective date. The court did not resolve the constitutional questions but based its decision on statutory construction and the doctrine of constitutional avoidance. View "DIAS v. BOONE" on Justia Law

In 2019, Nestle Purina Petcare Company sought to switch its electric supplier for its facility in Hartwell, Georgia, from Georgia Power Company to Walton Electric Membership Corporation. Georgia Power objected, citing the Territorial Electric Service Act, arguing that the premises were not new and did not meet the requirements to switch suppliers. Georgia Power contended that the premises had long been a manufacturing and warehousing facility and that the changes made by Nestle did not amount to the premises being "destroyed or dismantled" as required by the Act.The Georgia Public Service Commission (the "Commission") ruled in favor of Nestle, concluding that the premises were "destroyed or dismantled" and not "reconstructed in substantial kind," allowing Nestle to switch to Walton EMC. The superior court reversed this decision, finding that the premises were not "destroyed or dismantled" and that the modifications did not meet the statutory requirements. The Court of Appeals affirmed the superior court's decision.The Supreme Court of Georgia reviewed the case and concluded that the appropriate standard of review was abuse of discretion. The Court determined that the Commission's decision should have been upheld. The Court held that "destroyed or dismantled" does not require complete destruction but can include substantial dismantling or stripping away of significant components. The Court also found that the premises were not "reconstructed in substantial kind" due to the significant differences in structure and function between the old and new facilities. Consequently, the Supreme Court of Georgia reversed the Court of Appeals' decision, allowing Nestle to switch its electric supplier to Walton EMC. View "WALTON ELECTRIC MEMBERSHIP CORPORATION v. GEORGIA POWER COMPANY" on Justia Law

Shamar Dequan Wilson was convicted for his involvement in the robbery and death of Rashawn Mays and the attempted armed robbery of Adrian Bennett. The crimes occurred on January 22, 2020. Wilson was indicted by a Lowndes County grand jury on April 30, 2021, and charged with felony murder, armed robbery, attempted armed robbery, and possession of a firearm during the commission of a felony. At his trial in January 2022, the jury found Wilson guilty on all counts. He was sentenced to life with the possibility of parole for felony murder, along with additional concurrent and consecutive sentences for the other charges. Wilson filed a motion for a new trial, which was denied, and subsequently appealed.Wilson's appeal focused on the sufficiency of the evidence for his convictions of attempted armed robbery and the associated possession of a firearm during the commission of a felony. He argued that the evidence did not prove his guilt beyond a reasonable doubt for these specific counts. The trial court had denied his motion for a new trial, leading to his appeal to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the case and found that the evidence was sufficient to support Wilson's convictions. The court noted that Bennett's testimony indicated Wilson pointed a gun at him and demanded money, which Bennett interpreted as a demand for his own money. Although Wilson did not take Bennett's wallet and phone, the court concluded that a reasonable jury could infer that Wilson's intent was to avoid being seen by Bennett. Therefore, the court affirmed Wilson's convictions for attempted armed robbery and possession of a firearm during the commission of a felony. The judgment was affirmed, and all justices concurred. View "WILSON v. THE STATE" on Justia Law

Hector Garcia-Solis was convicted of malice murder and other crimes related to the shooting death of Hall County Deputy Sheriff Blane Dixon on July 7, 2019. Garcia-Solis, along with co-defendants Brayan Cruz, Eric Velazquez, and London Clements, was involved in a series of burglaries and thefts leading up to the fatal shooting. The group stole vehicles and firearms, and during a police chase, Garcia-Solis shot and killed Deputy Dixon. Garcia-Solis was sentenced to life in prison without the possibility of parole, plus additional consecutive years for other charges.The case was initially reviewed by a Hall County grand jury, which indicted Garcia-Solis and his co-defendants on multiple counts, including malice murder, felony murder, aggravated assault, and various theft-related charges. Cruz pleaded guilty to some charges and testified for the State. Garcia-Solis, Velazquez, and Clements were tried together, and the jury found Garcia-Solis guilty on all counts. The trial court sentenced him to life without parole for malice murder and additional consecutive years for other charges. Garcia-Solis filed a motion for a new trial, which was denied, leading to his appeal to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the case and affirmed Garcia-Solis's convictions and sentences. The court held that the evidence was sufficient to support the malice murder conviction, as Garcia-Solis intentionally shot Deputy Dixon, demonstrating an "abandoned and malignant heart." The court also found no merit in Garcia-Solis's claim that the trial court erred in denying his motion for a change of venue due to pretrial publicity, as the jury selection process did not show actual prejudice. Lastly, the court upheld the life without parole sentence, noting that the trial court properly considered Garcia-Solis's age and the egregious nature of his crimes. View "GARCIA-SOLIS v. THE STATE" on Justia Law

Henry Strickland contested the results of a city commissioner election in Waycross, Georgia, after losing to Alvin Nelson. Strickland argued that the election used an outdated 2005 map of voting districts instead of the correct 2011 map, resulting in 32 voters casting ballots in the wrong districts. The trial court agreed, finding that the use of the 2005 map could have affected the election outcome, which Nelson won by 18 votes. Consequently, the court vacated the election and ordered a new one to be held in November 2024 using the 2011 map.The trial court denied Nelson's motion to dismiss Strickland's petition for insufficient process and service of process and rejected Nelson's argument that the petition should be dismissed for lack of expeditious pursuit. The court found irregularities in the election due to the use of the 2005 map and ordered a new election. Nelson appealed the trial court's decision, and the Supreme Court of Georgia granted his request for a stay pending the appeal.The Supreme Court of Georgia reversed the trial court's judgment. The Court held that the 2011 map was never effective because the required filings with the Secretary of State and the clerk of the superior court, as mandated by OCGA § 36-35-5, were never made. Since the 2011 map was not effective at the time of the election, there was no basis for the trial court's conclusion that enough illegal or irregular votes were counted to change or cast doubt on the election outcome. Therefore, Strickland's petition was rejected, and the trial court's order vacating the election was reversed. View "NELSON v. STRICKLAND" on Justia Law

Rondriques Brundage was convicted of felony murder and possession of a firearm during the commission of a felony for the shooting death of Rodrell Matthews. The incident occurred on July 10, 2018, and Brundage was indicted on multiple charges, including malice murder and aggravated assault. At trial, Brundage was found not guilty of malice murder, felony murder predicated on aggravated assault, and aggravated assault, but guilty of felony murder predicated on possession of a firearm by a convicted felon, possession of a firearm by a convicted felon, possession of a firearm during the commission of a felony, and concealing the death of another. He was sentenced to life without parole for felony murder, plus additional consecutive prison terms for the other charges.Brundage filed a motion for a new trial, which was denied except for the merger of the possession of a firearm by a convicted felon count into the felony murder count. He appealed, arguing that his trial counsel was ineffective for failing to object to the State's incorrect explanation of self-defense as it applied to felony murder predicated on felon-in-possession and for failing to request a jury charge on the defense of habitation.The Supreme Court of Georgia reviewed the case and agreed with Brundage that his trial counsel was deficient for not objecting to the State's incorrect explanation of self-defense. The court found that this deficiency prejudiced Brundage, as it was reasonably probable that an objection would have led to a different outcome regarding the felony murder and possession of a firearm during the commission of a felony charges. Consequently, the court reversed Brundage's convictions on those counts, allowing for the possibility of retrial. The court affirmed Brundage's conviction for concealing the death of another, which was not challenged on appeal. The case was remanded for further proceedings consistent with the court's opinion. View "BRUNDAGE v. THE STATE" on Justia Law

Raiem Singleton was convicted of malice murder and other crimes related to the shooting death of Luz Selene Velazquez and the aggravated assault of David Montes-Ponce. The crimes occurred on May 5, 2017, when Montes-Ponce and Velazquez arranged to buy a phone from a seller named "Tom Li" through a mobile app. When they met the seller at an apartment complex, the seller, accompanied by two other men, shot at Montes-Ponce's car, killing Velazquez. Montes-Ponce identified Singleton as the shooter.A DeKalb County grand jury indicted Singleton on multiple charges, including malice murder and aggravated assault. Following a jury trial, Singleton was found guilty on all counts and sentenced to life in prison for malice murder, with additional concurrent and suspended sentences for other charges. Singleton filed a motion for a new trial, which was denied by the trial court after a hearing.The Supreme Court of Georgia reviewed Singleton's appeal, where he argued that the trial court erred in denying his motion to suppress identification evidence from a photo lineup. The court employed a two-step process to evaluate the identification procedure, considering whether it was impermissibly suggestive and whether there was a substantial likelihood of irreparable misidentification. The court found that even if the lineup was suggestive, there was no substantial likelihood of misidentification due to Montes-Ponce's significant opportunity to view Singleton during the crime and his high degree of certainty in identifying Singleton.The Supreme Court of Georgia affirmed the trial court's decision, holding that the trial court did not abuse its discretion in admitting the identification evidence and denying Singleton's motion to suppress. View "SINGLETON v. THE STATE" on Justia Law

Dontarious Burke was convicted of malice murder and armed robbery for the shooting death of Kentrell Jones. The incident occurred on November 27, 2019, and Burke was indicted on March 1, 2021. His trial was severed from his brother DeMarcus Burke's trial. Burke was tried by a jury from October 19 to 20, 2021, and found guilty on all counts. He was sentenced to life in prison for malice murder and an additional 20 years for armed robbery. Burke filed a motion for a new trial, which was denied by the trial court on May 6, 2024. He then filed a timely notice of appeal.The trial court denied Burke's motion for a new trial, and he appealed to the Supreme Court of Georgia. Burke raised several claims, including a violation of his Sixth Amendment rights under the Confrontation Clause, ineffective assistance of counsel, and the cumulative effect of errors requiring a new trial. The trial court had admitted testimony from police officers about information obtained from non-testifying witnesses, which Burke argued violated his Confrontation Clause rights. However, because Burke did not raise this objection at trial, the Supreme Court reviewed it for plain error and found none.The Supreme Court of Georgia reviewed Burke's claims and found that none of them warranted a reversal of his convictions. The court held that Burke's Confrontation Clause rights were not violated, as the testimony in question did not clearly and obviously violate established law. Additionally, the court found that Burke's trial counsel did not render ineffective assistance, as the decisions made by counsel were within the bounds of reasonable trial strategy. Finally, the court determined that there was no cumulative error that would require a new trial. Consequently, the Supreme Court of Georgia affirmed Burke's convictions. View "BURKE v. THE STATE" on Justia Law

Pascal Lorenzo Reddick was found guilty by a Grady County jury of felony murder and possession of a firearm during the commission of a felony, related to the shooting death of Antavius Robinson. The incident occurred when Robinson went to Reddick's home, where Reddick was with Robinson's wife, Lakeisha. Robinson banged on the door and shouted threats. Reddick fired two shots, one from inside the home and another from the porch, hitting Robinson as he retreated.The trial court sentenced Reddick to life in prison for felony murder and a consecutive five-year term for the firearm charge. Reddick's motion for a new trial was denied by the trial court. He argued that the evidence was insufficient to disprove his self-defense and defense of habitation claims, that the trial court erred in denying his immunity motion, and that his trial counsel was ineffective.The Supreme Court of Georgia reviewed the case and affirmed the convictions. The court held that the evidence was sufficient for a rational jury to find Reddick guilty beyond a reasonable doubt. The court noted that Robinson was unarmed and retreating when he was shot, and the forensic evidence supported the State's theory that Reddick fired the fatal shot from the porch. The court also found no abuse of discretion in the trial court's denial of Reddick's immunity motion, as the evidence did not support his defense of habitation claim.Regarding ineffective assistance of counsel, the court concluded that Reddick failed to show that his counsel's performance was deficient or that any alleged deficiencies prejudiced the outcome of the trial. The court found that counsel's decisions were within the bounds of reasonable trial strategy. Thus, the Supreme Court of Georgia affirmed the trial court's judgment. View "REDDICK v. THE STATE" on Justia Law