Justia Georgia Supreme Court Opinion Summaries

Victor Allen Smith was involved in a fatal collision on March 6, 2022, in Gwinnett County, Georgia, after attempting to evade a Georgia State Patrol trooper during a high-speed pursuit. Smith, driving a silver sports car, made improper lane changes and exceeded the speed limit, reaching speeds estimated at over 120 miles per hour. While fleeing, Smith’s vehicle veered onto the interstate shoulder where Hugo Nathaniel Martinez was waiting for his truck to be towed. Smith’s car struck and killed Martinez, who died from severe blunt-force injuries. Smith exhibited signs of intoxication at the scene, and subsequent toxicology tests revealed a blood alcohol concentration of 0.188. Evidence also showed that Smith’s driver’s license had been suspended since 2004.Smith was indicted by a Gwinnett County grand jury on multiple charges, including felony murder, homicide by vehicle, aggravated assault, fleeing or attempting to elude a police officer, driving under the influence, and other traffic offenses. Prior to trial, certain counts were dismissed, including driving while license suspended. At trial in the Superior Court of Gwinnett County, the jury found Smith guilty on all remaining counts. Smith was sentenced to life in prison without parole for felony murder, with additional concurrent sentences for other offenses. After the trial court denied his motion for a new trial, Smith appealed.The Supreme Court of Georgia reviewed Smith’s sole claim that the trial court abused its discretion by admitting evidence of his suspended driver’s license. Applying an abuse of discretion standard, the Supreme Court assumed, without deciding, that admitting the evidence may have been erroneous but found any error harmless due to the overwhelming evidence of Smith’s guilt and the minimal role the license suspension played at trial. The Court affirmed Smith’s convictions. View "SMITH v. THE STATE" on Justia Law

On the night of January 3, 2016, the defendant, along with two accomplices, planned and executed a burglary at the home of a family friend. The group traveled together to the residence, where they confronted the victim, Caleb Short, outside the house. The defendant and another accomplice forcibly subdued and bound Caleb with tape, then moved him to the backyard. Subsequently, the group entered the house, stole various items including vehicles, and left the scene. The next morning, law enforcement discovered the bodies of Caleb, his mother, and his niece, all of whom had suffered fatal injuries. Evidence linked the defendant to the stolen property and to actions taken before, during, and after the crimes.A Muscogee County grand jury indicted the defendant and his accomplices on multiple charges, including malice murder, felony murder, kidnapping, burglary, and theft by taking. At trial in the Superior Court of Muscogee County, the defendant’s co-defendants pleaded guilty, and the jury found the defendant guilty of felony murder (as to Caleb), kidnapping, burglary, and theft by taking, but could not reach a verdict on other counts, leading to a mistrial on those. The court sentenced the defendant to life imprisonment with the possibility of parole and additional concurrent and consecutive terms. The defendant’s motion for new trial was denied, and after procedural delays, he filed a timely appeal.The Supreme Court of Georgia reviewed the case and affirmed the convictions. The Court held that the evidence was sufficient to support the convictions, including as a party to the crimes. It found no abuse of discretion in admitting post-incision autopsy photographs, giving an Allen charge to the jury, denying a change of venue due to pretrial publicity, or refusing to impanel a new jury after the co-defendants pleaded guilty. The Court concluded that none of the alleged errors warranted reversal. View "BURKS v. THE STATE" on Justia Law

The case concerns a shooting that occurred on March 15, 2022, in Griffin, Georgia, resulting in the death of Wildarius Draggs and the assault of Rayshon Goodrum. Surveillance footage showed that Draggs and Goodrum were sitting on a porch when a car containing Isaac Reid, Kinesa Harvey, DeQuivon McMullin, and Cameron Barkley drove by. Later, Reid, McMullin, and Barkley exited the car, walked behind a nearby house, and shortly thereafter, shots were fired at Draggs and Goodrum. Barkley, a co-defendant, testified that Reid fired the shots, motivated by the belief that a rival gang member was present. Physical evidence included shell casings at the scene and a photograph of a gold gun allegedly used in the shooting. Draggs died from his injuries, and Goodrum survived.The Superior Court of Spalding County conducted a joint trial for Reid, Harvey, and McMullin. The jury acquitted Harvey of all charges, found Reid guilty of malice murder and other offenses (but not guilty on one gang-related count), and found McMullin guilty of aggravated battery and felony murder predicated on that battery. Reid was sentenced to life without parole plus consecutive sentences for aggravated assault and a gang violation. Reid filed a motion for new trial, which was denied. He then appealed.The Supreme Court of Georgia reviewed the case after it was transferred from the Court of Appeals. The Court held that the evidence was sufficient under federal due process standards to support Reid’s convictions, finding that the jury could reasonably conclude Reid was the shooter based on the surveillance footage, testimony, and corroborating evidence. The Court also found that the statutory requirement for corroboration of accomplice testimony was met. The denial of Reid’s motion for new trial was affirmed, and his convictions were upheld. View "REID v. THE STATE" on Justia Law

The case concerns the fatal shooting of Michael Riley in his home on June 30, 2013. Police investigation revealed that Riley’s wife, Antoinette Riley, and her daughter, Katrina Ledford, were involved in a plot to kill Riley, with Tarell Momon, who was incarcerated and romantically involved with Ledford, allegedly orchestrating the murder. Cell phone records showed extensive communication between Momon, Ledford, and Antoinette, as well as with two other individuals, Terrance Griswould and Travis Berrian, who were implicated as co-conspirators. The evidence included text messages indicating planning and coordination of the murder, and testimony about Momon’s gang affiliation and prison conduct.A Bulloch County grand jury indicted Momon, Griswould, Ledford, and Antoinette Riley for malice murder and possession of a firearm during the commission of a felony. Ledford and Antoinette pleaded guilty, while Momon and Griswould were tried together. The jury found Momon guilty of murder but acquitted him of the firearm charge; Griswould was acquitted on all counts. Momon was sentenced to life in prison with the possibility of parole. He filed a motion for a new trial, which was denied by the trial court after several amendments and delays.The Supreme Court of Georgia reviewed Momon’s appeal, in which he argued that his trial counsel was constitutionally ineffective for failing to make certain evidentiary objections and that the cumulative effect of these alleged errors denied him a fair trial. The court held that Momon failed to demonstrate either deficient performance by his counsel or resulting prejudice under the standard set by Strickland v. Washington. The court found that the challenged evidence was either admissible, cumulative, or not prejudicial, and that counsel’s decisions were within the bounds of reasonable trial strategy. The judgment of the trial court was affirmed. View "MOMON v. THE STATE" on Justia Law

The case concerns an individual who was charged with malice murder and related offenses after fatally stabbing a man with whom he had no prior relationship. On the day of the incident, the accused exhibited unusual behavior at work, left the premises, and later entered a bank where he appeared confused and reported hearing voices. After a police officer stopped him for a traffic violation, the accused was taken to a hospital and subsequently to a behavioral health facility. There, detectives interviewed him, and he admitted to the killing, describing delusional beliefs and auditory hallucinations. Forensic evidence linked him to the crime, and expert testimony at trial addressed his mental state, with differing opinions on whether his psychosis was drug-induced and whether he could distinguish right from wrong at the time of the offense.A Catoosa County grand jury indicted the accused on multiple counts, including malice murder. After a jury trial, he was found guilty but mentally ill of malice murder and other charges. The trial court sentenced him to life with the possibility of parole for malice murder and additional consecutive time for possession of a knife during the commission of a felony. The court vacated the felony murder count by operation of law and merged the aggravated assault count. The accused filed a motion for a new trial, which was denied by the trial court.On appeal to the Supreme Court of Georgia, the appellant argued that his statements to law enforcement at the behavioral health facility should have been suppressed because he was in custody and had not received Miranda warnings, and that the trial court erred in refusing certain jury instructions related to his insanity defense and voluntary intoxication. The Supreme Court of Georgia held that the appellant was not in custody for Miranda purposes during the interview, and that the trial court’s jury instructions adequately covered the applicable law. The court affirmed the convictions. View "GRAVITT v. THE STATE" on Justia Law

Tussahaw Reserves, LLC and Keys Ferry Crossing, LLC owned two parcels of land in Butts County, Georgia, zoned for agricultural and residential use. In 2020, they applied to rezone the property for use as a rock quarry, but the Butts County Board of Commissioners denied the applications in early 2021. Tussahaw then filed an “Appeal and Petition for Writ of Certiorari and Verified Complaint” in the Butts County Superior Court, challenging the Board’s decision. The complaint named the Board and its members as “respondents-in-certiorari” and the County as “defendant.” The claims included a writ of certiorari against the Board and its members, and alternative claims for declaratory and injunctive relief against the County.After the Board and its members filed an answer and moved to be discharged from the case, the superior court denied their motion. Following the Georgia Supreme Court’s decision in State v. SASS Group, Butts County moved to dismiss, arguing that the lawsuit violated the Georgia Constitution’s requirement that actions against a county be brought exclusively against the county and in its name. Tussahaw moved to drop the respondents-in-certiorari, but the superior court did not rule on that motion and instead dismissed the lawsuit, finding it barred by sovereign immunity. The Court of Appeals affirmed, reasoning that the substance of the complaint sought relief against the Board, not just the County.The Supreme Court of Georgia reviewed the case and held that failure to comply with the constitutional naming requirement is not a jurisdictional bar and does not preclude the trial court from considering motions to drop parties. The Court vacated the Court of Appeals’ decision and remanded the case for further proceedings, directing the superior court to vacate its dismissal order and address the pending motions. View "TUSSAHAW RESERVES, LLC v. BUTTS COUNTY" on Justia Law

In this case, the defendant was convicted of malice murder and other related offenses following the shooting death of one individual and the non-fatal shooting of another at a gas station in Chamblee, Georgia, in December 2016. The incident began with a brief confrontation inside the store, after which the defendant retrieved a gun and fired multiple shots at the victims as they attempted to leave. Surveillance footage and witness testimony supported the prosecution’s account, and evidence was presented regarding the defendant’s gang affiliation and prior criminal history. The defendant testified, admitting to the shooting but claiming self-defense, asserting that he believed one victim was armed and threatening.The case was tried in the Superior Court of DeKalb County, where a jury acquitted the defendant of one count of participation in criminal gang activity but found him guilty of malice murder, felony murder, aggravated assault, possession of a firearm by a convicted felon, and other charges. The trial court sentenced him to life without parole and additional consecutive terms for the other offenses. The felony murder conviction was vacated by operation of law, and one aggravated assault count merged into the malice murder count. After the verdict, the defendant filed a motion for new trial, which was denied following an evidentiary hearing.On appeal to the Supreme Court of Georgia, the defendant argued that his trial counsel was constitutionally ineffective in several respects, including failing to object to the admission of certain prior convictions and other evidence. The Supreme Court of Georgia held that the defendant failed to demonstrate either deficient performance by counsel or resulting prejudice sufficient to undermine confidence in the outcome. The judgment of the trial court was affirmed. View "COPNEY v. THE STATE" on Justia Law

After their property in DeKalb County was annexed by the City of Atlanta, two parents sought to enroll their children in Atlanta Public Schools (APS). APS, however, denied enrollment, citing a 2021 Georgia law (SB 209) that prevents the expansion of APS boundaries to include newly annexed areas unless specifically authorized. The City of Atlanta had approved the annexation and expressed its intent for the APS boundaries to expand accordingly, but APS maintained that SB 209 prohibited such an extension.The parents and the City of Atlanta filed a petition for declaratory and injunctive relief against the State of Georgia, arguing that SB 209 was unconstitutional under the Georgia Constitution’s Single Subject Rule. The case was initially filed in Fulton County, transferred to DeKalb County, and then refiled in Fulton County against the State after the plaintiffs voluntarily dismissed the DeKalb action. The DeKalb County School District (DCSD) was allowed to intervene as a plaintiff. The trial court denied motions to dismiss, found that the plaintiffs had standing, determined there was a justiciable controversy, and ruled that SB 209 violated the Single Subject Rule, granting declaratory and injunctive relief to the plaintiffs.On appeal, the Supreme Court of Georgia reviewed whether the trial court had jurisdiction to grant relief. The Supreme Court of Georgia held that the plaintiffs failed to establish an actual or justiciable controversy with the State, as the alleged harm stemmed from APS’s actions, not from any enforcement by the State. Because the dispute did not involve the parties before the court, the Supreme Court of Georgia vacated the trial court’s judgment and remanded the case with instructions to dismiss the petition. View "PILATO v. STATE OF GEORGIA" on Justia Law

The case concerns a man who lived with his father in Barrow County, Georgia, and was accused of killing a family friend who often stayed at their home. After the friend’s disappearance, the accused made suspicious statements to his father, and the friend’s body was later found in the trunk of his own car, having been shot multiple times. The accused was apprehended after fleeing from law enforcement, and during post-arrest interviews, he admitted to the killing and provided details that were corroborated by physical evidence. At trial, he testified that he shot the victim after a confrontation related to past sexual abuse and introduced evidence about his methamphetamine use and its effects.A Barrow County grand jury indicted the accused on multiple charges, including malice murder, felony murder, aggravated assault, firearm possession during a felony, concealing a death, and methamphetamine possession. After a jury trial in the Superior Court of Barrow County, he was found guilty on all counts. The court sentenced him to life plus eighteen years in prison, with certain counts merging or being vacated as a matter of law. The defendant’s motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed three main claims: the failure to give a jury instruction on voluntary intoxication, the admission of prior-act evidence under Georgia’s Rule 404(b), and the admission of his post-arrest statements. The Court held that the trial court properly declined the requested intoxication instruction because it misstated the law, any error in admitting the prior-act evidence was harmless given the overwhelming evidence of guilt, and the admission of the defendant’s statements did not violate due process because there was no evidence of police coercion. The Supreme Court of Georgia affirmed the convictions. View "WOSCHULA v. THE STATE" on Justia Law

The case concerns the killing of Regina Trotter, who lived in Alabama with Micah Blake Taylor and another individual. On January 31, 2021, Taylor took Trotter’s van without her permission. After returning the van, Trotter told Taylor he could no longer stay at her home. She agreed to drive Taylor and Jenae Dickinson back to Dickinson’s residence. During the drive, Taylor strangled Trotter after Dickinson directed Trotter down a dirt road. Taylor then pulled Trotter into the back of the van, and after a struggle, removed her from the vehicle. Trotter’s body was found the next day with evidence of strangulation and sharp-force injuries. Physical evidence, including DNA and items found at the scene, linked Taylor to the crime. Taylor was later found asleep in Trotter’s stolen van.A Heard County grand jury indicted Taylor and Dickinson. Dickinson pleaded guilty to lesser charges and testified against Taylor. In March 2023, a jury in the Superior Court of Heard County found Taylor guilty of malice murder and related offenses. He was sentenced to life without parole plus a consecutive ten-year term. Taylor’s motion for a new trial was denied by the trial court in September 2024. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Taylor’s claims that the trial court erred in admitting evidence obtained from his Facebook account and cell phone records, arguing the warrants lacked probable cause. The Court held that even if the warrants were deficient, any error was either not plain or was harmless beyond a reasonable doubt because the challenged evidence was cumulative of other properly admitted evidence and the evidence of Taylor’s guilt was overwhelming. The Court affirmed the judgment of the trial court. View "TAYLOR v. THE STATE" on Justia Law