Justia Georgia Supreme Court Opinion Summaries

In January 2015, Kristian Wipfel, along with Dennis Eason, Jr., Tevin Sams, Antonio Garvin, and Jeremy Jackson, confronted Dejad Williams over a drug dispute. The confrontation led to a shooting at Williams's apartment, resulting in the death of eight-year-old Jai’mel Anderson. Wipfel was indicted for malice murder, felony murder, aggravated assault, making terroristic threats, and firearm possession during a felony. At trial, Garvin and Jackson testified against Wipfel, Eason, and Sams. The jury found Wipfel guilty of all charges except making terroristic threats.The trial court sentenced Wipfel to life without parole for malice murder, 20 years for aggravated assault, and consecutive five-year terms for the firearm offenses. Wipfel's motion for a new trial was denied, and his subsequent appeal was dismissed due to procedural issues. After rectifying the notification issue, Wipfel filed a timely appeal.The Supreme Court of Georgia reviewed Wipfel's claim that the trial court erred by not instructing the jury on involuntary manslaughter as a lesser offense of malice murder. Wipfel argued that his actions amounted to reckless conduct rather than malice murder. The court applied the plain error review standard, which requires showing that the error was clear, affected the trial's outcome, and impacted the fairness of the proceedings.The court held that the trial court did not err in failing to give the involuntary manslaughter instruction sua sponte, as Wipfel did not request it. The court reaffirmed the rule from State v. Stonaker, which states that a trial court's failure to instruct on a lesser offense without a request is not error. Consequently, Wipfel's claim of plain error failed, and the court affirmed his conviction. View "WIPFEL v. THE STATE" on Justia Law

Markisha Lattimore obtained a judgment exceeding $20 million against Kim Brothers Kickin’ Kids, LLC. Instead of collecting directly from Kickin’ Kids, Lattimore initiated garnishment actions against twelve financial services companies, including RBC Global Asset Management (U.S.), Inc. (Global), using a garnishment summons form for financial institutions. Global, a registered investment advisor, did not respond to the summons, leading Lattimore to move for a garnishment default judgment for the full amount. Global claimed it did not receive the motion and did not respond. The State Court of Fulton County entered a default judgment against Global.The State Court of Fulton County denied Global’s motion to set aside the default judgment. The court ruled that Global was a financial institution, that Lattimore used the correct summons form, and that Global waived any defect in the form used. Global argued that it was not a financial institution as defined by the statute and that the incorrect summons form invalidated the garnishment action, thus failing to establish personal jurisdiction. The court also ruled that Global could not challenge the constitutionality of the default judgment in its motion to set aside.The Supreme Court of Georgia reviewed the case and reversed the lower court’s decision. The court held that Global, as a registered investment advisor, did not meet the statutory definition of a financial institution. Therefore, Lattimore used the wrong summons form, rendering the garnishment invalid and failing to obtain personal jurisdiction over Global. The court concluded that the State Court of Fulton County abused its discretion in denying Global’s motion to set aside the default judgment. The judgment was reversed. View "RBC GLOBAL ASSET MANAGEMENT (U.S.) INC. v. LATTIMORE" on Justia Law

In this case, the appellant was convicted of malice murder and other crimes related to the shooting death of a woman. The incident occurred on August 22, 2014, when the victim was found dead and burned at a city dump. Evidence linked the appellant, a police officer, to the crime through cell phone records, DNA, and ballistic tests. The appellant admitted to meeting the victim for sex but claimed the shooting was accidental during a struggle over a gun.The Fulton County grand jury indicted the appellant on multiple charges, including malice murder, felony murder, and aggravated assault. A jury trial held in October 2016 resulted in the appellant being found guilty on all counts. The trial court sentenced him to life in prison without parole for malice murder and additional consecutive sentences for other charges. The appellant's motion for a new trial was denied by the trial court in November 2023.The Supreme Court of Georgia reviewed the case and addressed several claims of error by the appellant. The court concluded that any error in limiting the defense of accident to the aggravated assault charge was harmless, as the jury found the appellant guilty of malice murder, which required a finding of malicious intent. The court also found no error in the trial court's refusal to charge the jury on the defense of habitation, as there was no evidence the victim was entering or attacking the appellant's car when shot. Lastly, the court determined that the appellant failed to establish plain error regarding the jury instructions on justification. Consequently, the Supreme Court of Georgia affirmed the appellant's convictions. View "RANA v. THE STATE" on Justia Law

Michael Earl Summerville was convicted of felony murder in connection with the death of Martha West. On December 10, 2017, Summerville and West, who were romantic partners, visited their neighbor Johnny Clark. After an argument, Summerville returned to Clark’s home later that night, reporting that West had fallen in a nearby field. West was found deceased in the field, with evidence suggesting she had been struck by a vehicle. Summerville’s truck showed signs of a collision, and fibers consistent with West’s clothing were found on the truck. An autopsy revealed extensive injuries consistent with being struck by a motor vehicle.A Wilkes County grand jury indicted Summerville for malice murder, felony murder predicated on aggravated assault, and aggravated assault, family violence. He was found not guilty of malice murder but guilty of the remaining charges. The trial court sentenced him to life in prison for felony murder, with the aggravated assault charge merging for sentencing purposes. Summerville’s motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Summerville’s claims of ineffective assistance of counsel and trial court error. Summerville argued that his trial counsel was ineffective for not objecting to a comment in the State’s closing argument and that the trial court improperly limited cross-examination of a witness. The court held that the prosecutor’s comment during closing arguments was a permissible inference from the evidence, and thus, any objection would have been meritless. Additionally, the court found no abuse of discretion in limiting the cross-examination of the medical examiner, as Summerville failed to show that the examiner’s prior disciplinary action was probative of potential bias. The court affirmed the trial court’s judgment. View "Summerville v. State" on Justia Law

Willie Felix Thompson was convicted of malice murder and other crimes related to the shooting death of Felicia Sullivan. Thompson and Sullivan had a tumultuous relationship marked by several violent incidents. On April 19, 2021, Thompson returned to their shared residence to collect his belongings but ended up shooting Sullivan during an altercation. Thompson claimed self-defense, stating that Sullivan attacked him first. However, forensic evidence and witness testimonies contradicted his account.A Cobb County grand jury indicted Thompson on charges including malice murder and aggravated assault. During the trial, the jury found him guilty on all counts. The trial court sentenced him to life in prison without parole for malice murder and an additional five years for the weapons charge. Thompson's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case and upheld the convictions. The court found that the evidence presented at trial was sufficient to support the jury's verdict. The court also determined that the trial court did not err in its jury instructions regarding prior-bad-acts and prior-difficulties evidence. The Supreme Court concluded that Thompson failed to demonstrate any clear or obvious error in the jury instructions and affirmed the lower court's decision. View "THOMPSON v. THE STATE" on Justia Law

In March 2020, the appellant was convicted of malice murder and related charges for the shooting death of Mondavius Milan. The incident occurred on April 3, 2018, in Atlanta, involving a check fraud scheme with the appellant, Milan, and Jaleesia Mathis. On the morning of the shooting, the group, including Mathis's partner Japhar White, was in a car when an argument over missing money escalated. Witnesses testified that the appellant pulled out a gun, and after a struggle, Milan was shot. Both Mathis and White fled the scene, later identifying the appellant as the shooter. The appellant was arrested in Massachusetts and extradited to Georgia.The appellant was indicted by a Fulton County grand jury and found guilty on all counts by a jury. The trial court sentenced him to life in prison for malice murder and additional consecutive sentences for firearm charges. The appellant's motion for a new trial was denied by the trial court after an evidentiary hearing. The appellant then filed a timely notice of appeal.The Supreme Court of Georgia reviewed the case, focusing on two main contentions: ineffective assistance of counsel and insufficient evidence. The court held that the appellant's trial counsel was not ineffective for advising him not to testify, as the counsel's advice was based on reasonable strategic considerations. The court also found that the evidence, including corroborating testimony from accomplices and other witnesses, was sufficient to support the conviction. The court affirmed the trial court's judgment, concluding that the appellant's claims lacked merit. View "NABORS v. THE STATE" on Justia Law

Chrishon Siders was convicted of murder and other crimes related to the shooting death of Seine Yale Jackson. On January 6, 2016, Siders, along with Haleem Graham and Brantley Washington, drove to Jackson’s home to purchase drugs. Siders was identified near the scene by a witness, and Jackson was found dead shortly after. Evidence included cell phone data, surveillance footage, and witness testimony linking Siders and his co-defendants to the crime. Siders testified, denying involvement and claiming he was elsewhere during the murder.The Fulton County Superior Court held a joint trial for Siders, Graham, and Washington, resulting in guilty verdicts for all charges against Siders. He was sentenced to life in prison without parole for malice murder, with additional consecutive sentences for other charges. Siders filed a motion for a new trial, which was denied. He then sought an out-of-time appeal, which was initially granted but later vacated following a change in procedural law. Siders subsequently filed a habeas corpus petition, which was granted, allowing him to file an out-of-time appeal.The Supreme Court of Georgia reviewed the case and affirmed the lower court’s decision. The court held that the evidence was sufficient to support Siders' convictions, rejecting his claims of insufficient evidence and errors in the trial court’s handling of evidence and jury instructions. The court found no abuse of discretion in admitting social media posts and hearsay statements, and it determined that the trial court’s responses to jury questions and instructions on witness credibility were appropriate. The court concluded that Siders' arguments did not demonstrate any reversible error. View "SIDERS v. THE STATE" on Justia Law

In October 2015, a jury found Dolonte Tedder guilty of malice murder and related crimes connected to the shooting death of Quleon Glass. The incident occurred on September 8, 2014, and Tedder, along with co-indictees Jacquavious Eggleston and Teandria Tabb, was indicted for various offenses. Tedder was tried alone and found guilty on all counts. He was sentenced to life in prison for malice murder, with additional concurrent and consecutive terms for other charges. Tedder filed a motion for a new trial, which was partially granted due to ineffective assistance of counsel. The case was remanded, and after further proceedings, the trial court denied the motion for a new trial.The Supreme Court of Georgia reviewed the case following the trial court's denial of Tedder's motion for a new trial. Tedder argued that the evidence was insufficient to sustain his convictions, that the trial court committed reversible errors, and that his trial counsel was constitutionally ineffective. The court found that the evidence presented at trial was sufficient to support Tedder's convictions for malice murder, aggravated assault, and possession of a firearm during the commission of a felony. The court also concluded that the evidence was sufficient to establish that Yung Fame was a criminal street gang and that Tedder was associated with it.The Supreme Court of Georgia affirmed the trial court's decision, holding that the trial court did not err in denying Tedder's motion for a directed verdict and that the evidence was sufficient to support his convictions. The court also found no error in the trial court's response to a jury question during deliberations and upheld the exclusion of juror affidavits under Rule 606(b). Finally, the court rejected Tedder's claims of ineffective assistance of counsel, concluding that his trial counsel's performance was not deficient and that Tedder failed to demonstrate prejudice. View "TEDDER v. THE STATE" on Justia Law

In August 2014, Joandre Robbins was involved in the shooting death of Wayne Edwards. Robbins and Michael Thompson were indicted for malice murder and felony murder predicated on aggravated assault. Thompson pled guilty to a reduced charge and received probation, while Robbins was found guilty on both counts and sentenced to life in prison for malice murder. Robbins appealed, arguing that the trial court erred in excluding photographs of Edwards holding guns and that his trial counsel was ineffective.The Chatham County Superior Court handled the initial trial. Robbins was convicted by a jury, and the trial court sentenced him to life imprisonment. Robbins filed a motion for a new trial, which was denied after amendments and a hearing. Robbins then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Robbins's claims. The court held that even if the trial court erred in excluding the photographs, the error was harmless given the other evidence presented at trial. The court also found that Robbins's trial counsel was not constitutionally ineffective. The court reasoned that the decision not to object to the State's closing argument about parole was a strategic choice, and the jury instructions on self-defense and implied malice were appropriate. The court concluded that Robbins did not demonstrate that the outcome of the trial would have been different but for his counsel's actions. Consequently, the Supreme Court of Georgia affirmed Robbins's conviction and sentence. View "ROBBINS v. THE STATE" on Justia Law

David Dajuanta Wallace was convicted of felony murder and a firearm offense related to the shooting death of Darius Bottoms. Wallace argued that the evidence was insufficient, that his due process rights were violated by being required to wear a leg iron and prison clothing during the trial, and that he received ineffective assistance of counsel.A Fulton County grand jury indicted Wallace and two co-defendants for various crimes, including felony murder and gang activity. Wallace pled guilty to some charges and went to trial on others. The jury found him guilty of felony murder and a firearm offense. The trial court sentenced him to life in prison with the possibility of parole for felony murder and an additional five years for the firearm charge. Wallace's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case and found that the evidence was sufficient to support Wallace's convictions. The court held that the testimony of an accomplice was corroborated by other evidence, satisfying Georgia statutory law. Constitutionally, the evidence allowed the jury to find Wallace guilty as a party to the crimes rather than merely an accessory after the fact. The court also determined that any error related to Wallace wearing a leg iron was harmless beyond a reasonable doubt, given that the jury could not see the leg iron, Wallace used it strategically, and the strong evidence of his guilt.Regarding ineffective assistance of counsel, the court concluded that Wallace failed to show either deficiency or prejudice. The court affirmed Wallace's convictions and the trial court's rulings. View "WALLACE v. THE STATE" on Justia Law