Justia Georgia Supreme Court Opinion Summaries

The case concerns a woman who was convicted of felony murder and aggravated assault following the shooting death of her husband in 2008. The incident occurred during a period of marital discord and financial stress. The defendant called 9-1-1, initially reporting that her husband had shot at her and then shot himself. However, physical evidence and witness testimony, including that of her young daughter, suggested multiple gunshots and circumstances inconsistent with suicide. The defendant gave varying accounts to law enforcement, at times claiming self-defense, accident, or that her husband shot himself.After her initial conviction in the Superior Court of Coweta County, the Georgia Supreme Court affirmed the verdict. Subsequent habeas proceedings in state and federal courts led to a finding by the United States Court of Appeals for the Eleventh Circuit that her appellate counsel had been ineffective, resulting in an order for a new trial. The trial court set aside her conviction, and at the 2019 retrial, a jury again found her guilty of felony murder and aggravated assault. The trial court merged the assault count for sentencing and imposed a life sentence. The defendant’s motion for a new trial was denied, and she appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed several evidentiary issues. It held that the trial court erred in admitting evidence of the defendant’s prior acts of violence against ex-husbands to show motive, as this constituted improper propensity evidence. However, the court found that the same evidence was properly admitted to show intent and absence of mistake or accident. The court also held that the admission of the daughter’s recorded statements was either proper or, if erroneous, harmless. The court concluded that any cumulative error did not deprive the defendant of a fair trial and affirmed the conviction. View "HALL v. THE STATE" on Justia Law

The case concerns a defendant who was convicted of three counts of malice murder and several related firearm offenses after the shooting deaths of three individuals in Savannah, Georgia. The defendant, a member of a criminal street gang, admitted to shooting the victims but claimed he acted in self-defense, citing a perceived threat during a gathering where all parties were armed and under the influence of drugs. Physical evidence, including ballistics and fingerprints, linked the defendant to the crime scene, and he was apprehended after a high-speed chase in a vehicle rented by one of the victims. The defendant gave multiple recorded statements to law enforcement, admitting to the shootings and describing his belief that he was in danger.A Chatham County jury found the defendant guilty on all counts, and the trial court imposed three concurrent life sentences without parole for the murders, along with additional sentences for firearm offenses. The defendant’s motion for a new trial was denied by the trial court. On appeal, the defendant argued that the trial court erred by not instructing the jury on voluntary manslaughter, that his trial counsel was ineffective in several respects, that cumulative errors warranted a new trial, and that his post-conviction counsel was also ineffective.The Supreme Court of Georgia reviewed the case and rejected all of the defendant’s claims. The court held that there was no plain error in failing to instruct the jury on voluntary manslaughter, as the evidence did not show sufficient provocation. The court also found no ineffective assistance of counsel, either at trial or post-conviction, and determined that any assumed errors did not prejudice the outcome. The court affirmed the convictions and sentences. View "MARROW v. THE STATE" on Justia Law

The case concerns a shooting that occurred in Bibb County, Georgia, in July 2021. The defendant called 911 and reported that he had shot his roommate and friend. When law enforcement arrived, the defendant made several unsolicited statements admitting to the shooting and expressing that he had wanted to kill the victim. Physical evidence and testimony established that the victim was shot in the back from a distance, and the autopsy confirmed homicide as the cause of death. The State also introduced evidence of the defendant’s prior felony conviction.A Bibb County grand jury indicted the defendant for malice murder, felony murder predicated on possession of a firearm by a convicted felon, and possession of a firearm by a convicted felon. At trial in the Superior Court of Bibb County, the jury found the defendant guilty on all counts. The trial court sentenced him to life in prison for malice murder, merged the possession count into the felony murder count, and then vacated the felony murder count. The defendant filed a motion for new trial, which was denied after a hearing. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the defendant’s claim that his trial counsel was ineffective for allegedly failing to properly advise him of his right to testify. The Court held that the record did not show that counsel advised the defendant not to testify, nor that any such advice would have been unreasonable. The Court found no evidence of deficient performance by counsel and concluded that the defendant failed to meet his burden under Strickland v. Washington. Accordingly, the Supreme Court of Georgia affirmed the judgment. View "WOODS v. THE STATE" on Justia Law

The case concerns Dominique Richardson, who was convicted of malice murder and related offenses following the shooting death of Taylor Holcombe. Richardson and Holcombe were in a relationship, and on the day of the incident, Richardson, Holcombe, and Cedric Porter spent time together, including picking up Porter and stopping at a gas station. Porter testified that Richardson suddenly pulled a gun on Holcombe while driving, after which Holcombe fled the car and Richardson shot her. Richardson then threatened Porter and later took steps to cover up the crime, including burning Holcombe’s car. Evidence at trial included Porter’s eyewitness account, testimony from a medical examiner, cell phone location data, and statements from a friend, Dontavious Davis, to whom Richardson allegedly confessed.A DeKalb County jury found Richardson guilty on all counts, and the trial court sentenced him to life without parole for malice murder, with additional time for firearm possession. The aggravated assault count merged, and the felony murder count was vacated by operation of law. Richardson’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 Richardson’s claims that the evidence was insufficient and that the trial court erred in admitting an audio recording of a witness’s prior statement. The Court held that the evidence, including direct eyewitness testimony and corroborating evidence, was sufficient to support the convictions under both federal and Georgia law. The Court also found that any error in admitting the audio recording was harmless given the strength of the other evidence. The Supreme Court of Georgia affirmed Richardson’s convictions. View "RICHARDSON v. THE STATE" on Justia Law

A woman, acting as conservator for her mother, filed a lawsuit alleging medical malpractice and ordinary negligence against a hospital and a nurse practitioner. The mother had suffered a stroke, became permanently disabled, and was transferred to the hospital for long-term care. During her stay, she developed a severe tongue injury that ultimately required amputation. The conservator was appointed nearly two years after the injury, and the lawsuit was filed more than two years after the alleged malpractice occurred. The plaintiff argued that the statute of limitations should be tolled due to the mother’s mental incompetence.The Superior Court granted the defendants’ motion to dismiss, finding that the two-year statute of limitations for medical malpractice actions under Georgia law was not tolled for mental incompetence, based on the “nontolling” provision in OCGA § 9-3-73(b). The court relied on the Supreme Court of Georgia’s prior decision in Deen v. Stevens, which upheld the constitutionality of this provision. The Court of Appeals affirmed, holding that it was bound by Deen and rejecting the plaintiff’s equal protection challenge to the statute.The Supreme Court of Georgia reviewed whether Deen controlled the case and whether the statute’s treatment of mentally incompetent medical malpractice plaintiffs violated the Equal Protection Clause. The court held that Deen was controlling and that the statute’s classification was subject to rational basis review. The court found that the legislative decision not to toll the statute of limitations for mentally incompetent plaintiffs in medical malpractice cases was rationally related to legitimate state interests, such as ensuring affordable healthcare and preventing stale claims. The court also rejected new arguments regarding the expert affidavit requirement. The judgment of the Court of Appeals was affirmed. View "WILLIAMS v. REGENCY HOSPITAL COMPANY, LLC" on Justia Law

The case concerns the method by which county tax assessors in Georgia determine the fair market value of properties that qualify for federal low-income housing tax credits under Section 42 of the Internal Revenue Code. The property owner, who operates a Section 42 affordable housing complex, challenged the county’s assessment of the property’s value for tax purposes. The dispute centers on whether tax assessors may use the “income approach”—a method that estimates value based on projected income streams—when valuing such properties, given statutory limitations on how Section 42 tax credits may be considered as income.After the county tax assessors issued a notice valuing the property, the owner appealed to the Superior Court of Lowndes County. The assessors moved for partial summary judgment, arguing that, under existing precedent, the income approach could not be used because Section 42 tax credits do not generate “actual income” for the property owner. The trial court agreed and granted summary judgment on this issue. The Georgia Court of Appeals affirmed, relying on its prior decision in Freedom Heights, LP v. Lowndes County Board of Tax Assessors, which interpreted both the relevant statute and Supreme Court of Georgia precedent as prohibiting use of the income approach under these circumstances.The Supreme Court of Georgia reviewed the case to clarify the proper interpretation of the statute and its own precedent. The court held that tax assessors are permitted to use the income approach to determine the fair market value of Section 42 properties, even though Section 42 tax credits, as currently structured, may not be treated as “income” under that approach. The court overruled the contrary holding in Freedom Heights, reversed the judgment of the Court of Appeals, and remanded the case for further proceedings. View "GATEWAY PINES HAHIRA, LP v. LOWNDES COUNTY BOARD OF TAX ASSESSORS" on Justia Law

P&J Beverage Corporation filed a lawsuit against the City of Columbus, seeking to prevent the city from issuing an alcoholic beverage license to The Bottle Shop, LLC, and later sought to revoke the license after it was issued. P&J argued that The Bottle Shop’s location was too close to a daycare, which it claimed qualified as a “school” under city ordinances. The trial court granted summary judgment to P&J, invalidating The Bottle Shop’s license and enjoining its operation. The Bottle Shop’s attorney then emailed P&J’s attorney, referencing a potential claim for wrongful injunction if the appellate court reversed the trial court’s order, and requested a stay of the injunction pending appeal. P&J declined, and The Bottle Shop’s motion for a stay was denied by the trial court but later granted by the Court of Appeals, which ultimately reversed the trial court’s decision on the merits.Subsequently, The Bottle Shop sued P&J for both abusive litigation and wrongful injunction, seeking damages, attorney fees, and punitive damages. At trial, The Bottle Shop presented evidence of lost revenue, overhead costs, and attorney fees incurred during the period it was closed. The jury awarded substantial damages, attorney fees, and punitive damages. The trial court entered judgment accordingly. P&J moved for a directed verdict and for judgment notwithstanding the verdict, arguing, among other things, that The Bottle Shop failed to provide the statutory notice required for an abusive litigation claim. The trial court denied these motions, and the Court of Appeals affirmed, holding that the email satisfied the statutory notice requirement.The Supreme Court of Georgia reviewed the case and held that the email sent by The Bottle Shop did not satisfy the statutory notice requirement under OCGA § 51-7-84 (a) for an abusive litigation claim, as it failed to identify the civil proceeding as abusive litigation. The Court vacated the trial court’s judgment and remanded the case for further proceedings to determine what portion of the damages, if any, remain valid. View "P& J BEVERAGE CORPORATION v. THE BOTTLE SHOP, LLC" on Justia Law

The case concerns the fatal shooting of Jamaal Smith during an attempted robbery at an apartment complex in Warner Robins, Georgia, on November 16, 2020. On the night of the incident, Smith and two friends, Moss and Brown, accompanied Terrence Rouse to the complex, where Rouse intended to buy marijuana. Testimony established that Rouse, armed with a gun, persuaded Smith to accompany him to an apartment, where a confrontation and shooting occurred. Smith was shot and later died at the hospital. Moss and Brown, who were present at the scene, identified Rouse as the perpetrator. Physical evidence included a handprint on the car used to transport Smith and ballistics evidence, though the latter was inconclusive as to the fatal bullet’s source.After the incident, Rouse was indicted on multiple counts, including three counts of felony murder predicated on different felonies, as well as related charges. He was tried individually in the Superior Court of Houston County and found guilty on all counts except for possession of a firearm by a convicted felon, which was nolle prossed. The trial court sentenced Rouse to life with the possibility of parole on one count of felony murder, merging the remaining counts. Rouse’s motion for a new trial was denied.On appeal to the Supreme Court of Georgia, Rouse argued that the evidence was insufficient to support his conviction, that his trial counsel was ineffective for not publishing certain jail letters to the jury, and that the trial court erred in admitting testimony about a prior drug deal. The Supreme Court of Georgia held that the evidence was sufficient, counsel’s actions were reasonable trial strategy, and the evidentiary rulings were not an abuse of discretion. The court affirmed the conviction and sentence. View "ROUSE v. THE STATE" on Justia Law

The case concerns the fatal stabbing of Jason Cason, Jr. on November 10, 2022. Cason lived with Gary Mack, who testified that on the day of the incident, George Sharrod Johns, a friend and frequent visitor, entered Cason’s bedroom. Mack heard Cason plead, “[D]on’t hit me no more,” and soon after, saw Johns leave the apartment alone. Mack discovered Cason unresponsive and covered in blood, then saw Johns attempt to re-enter the apartment before leaving the area. Police later found bloodstains in Johns’s apartment matching Cason’s DNA. Forensic evidence established that Cason suffered 27 stab wounds, including defensive injuries, and died rapidly from chest wounds.A Fulton County grand jury indicted Johns for malice murder, felony murder, and aggravated assault. After a jury trial in December 2023, Johns was convicted on all counts. The trial court sentenced him to life in prison for malice murder, merging or vacating the other counts. Johns filed a motion for new trial, which was denied by the Superior Court of Fulton County in September 2024. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Johns’s claims that the evidence was insufficient, that the trial court erred in admitting certain autopsy photographs, and that his Confrontation Clause rights were violated by the testimony of a medical examiner who did not perform the autopsy. The court held that the evidence was constitutionally sufficient to support the conviction, the trial court did not abuse its discretion in admitting the autopsy photographs, and there was no Confrontation Clause violation because the testifying expert provided an independent opinion rather than relaying another’s findings. The court affirmed Johns’s convictions and sentence. View "JOHNS v. THE STATE" on Justia Law

In this case, the defendant was charged in connection with the armed robbery and murder of an individual named Deontavious Wright. The incident occurred when three men, including the defendant, entered an apartment where Deontavious lived, along with several other people and two young children. One of the men, Rucker, held Deontavious at gunpoint, demanded drugs and money, and ultimately shot Deontavious multiple times after taking his possessions. The defendant was identified by three eyewitnesses who recognized him despite his mask, based on his clothing, physical features, and voice. Cell phone location data also placed the defendant near the scene at the relevant time. The defendant and his alibi witness testified that he was elsewhere during the crime.The Superior Court of Fulton County conducted a joint jury trial for the defendant and his co-defendants. The jury found the defendant guilty of felony murder predicated on home invasion, armed robbery, aggravated assault, cruelty to children, and firearm possession offenses, but acquitted him of malice murder and one count of aggravated assault. The court sentenced him to life imprisonment and additional terms for the other convictions. The defendant filed a motion for a new trial, which was denied, and then appealed.The Supreme Court of Georgia reviewed the case. It held that the evidence was constitutionally sufficient to support the convictions, as the jury was entitled to credit the eyewitness identifications and the corroborating cell phone evidence. The Court also found that the trial court did not err in admitting a co-defendant’s non-testimonial statements under Bruton v. United States, as those statements were not made for prosecutorial purposes. Finally, the Court held that the trial court did not abuse its discretion in denying the defendant’s motion to sever his trial from his co-defendants. The Supreme Court of Georgia affirmed the convictions. View "IVORY v. THE STATE" on Justia Law