Justia Georgia Supreme Court Opinion Summaries

The Georgia Supreme Court granted certiorari review to consider whether the Court of Appeals erred in reversing a trial court’s order confirming an arbitration award against Interstate National Dealer Services, Inc. (“INDS”), in favor of Southern Mountain Adventures, LLC (“Dealer”), and Adventure Motorsports Reinsurance Ltd. (“Reinsurer”). The dispute arose from the parties’ contractual relationship pursuant to which Dealer sold motorsports vehicle service contracts, which were underwritten and administered by INDS, to Dealer’s retail customers, and Reinsurer held funds in reserve to pay covered repair claims. The Supreme Court concluded the Court of Appeals erred in reversing the confirmation of the award because the arbitrator manifestly disregarded the law in rendering the award. In Case No. S21G0015, the Supreme Court reversed the Court of Appeals’ decision reversing the order confirming the arbitration award on that basis, and remanded for resolution of INDS’s argument that the arbitrator overstepped his authority in making the award. In Case No. S21G0008, the Supreme Court vacated the Court of Appeals’ decision dismissing as moot Dealer and Reinsurer’s appeal of the trial court’s failure to enforce a delayed-payment penalty provided in the arbitration award, and remanded for reconsideration of that issue. View "Adventure Motorsports Reinsurance, Ltd., et al. v. Interstate National Dealer Services, Inc." on Justia Law

In February 2018, Plaintiff filed a lawsuit on behalf of himself and a putative class of similarly situated persons against Defendants RCC Wesley Chapel Crossing, LLC, Little Giant Farmers Market Corporation, Dollar Tree Stores, Inc., River City Capital, LLC, and River City Capital Property Management, LLC for negligence, premises liability, false imprisonment, conversion, and violation of the Georgia Racketeer Influenced and Corrupt Organizations Act (“RICO”). Plaintiff claimed that Defendants “hired, authorized, or otherwise provided material support to” third parties that immobilized vehicles located on Defendants’ property with boots or similar devices, and required the owners or operators of the vehicles to pay a fee in order to have the immobilizing devices removed. Plaintiff moved to certify the action on behalf of a proposed class of similarly situated persons, claiming that between February 2013 and 2018, at least 250 persons “have been booted and have paid a fine for removal of said device” at the Wesley Chapel Lot. Following briefing and oral argument, the trial court granted Plaintiff’s motion, certifying the class. The Georgia Supreme Court granted certiorari in this case to decide whether there was a common-law right that permits private property owners to immobilize vehicles that were not authorized to be on their property. The Court concluded that the common-law rights the defendants alluded to in the courts below – namely, the right to remove trespassing vehicles and an alleged right to impound trespassing vehicles – did not apply to the defendants’ vehicle immobilization practice. However, because the Supreme Court disagreed with the Court of Appeals’ conclusion that “the trial court did not err in finding no common law right to immobilize a vehicle absent an enabling statute or ordinance,” and any reliance on that conclusion in affirming the trial court’s order granting Plaintiff Forrest Allen’s motion for class certification, the Supreme Court vacated the judgment of the Court of Appeals and remanded the case with direction to remand to the trial court for reconsideration of the proposed class. View "RCC Wesley Chapel Crossing, LLC et al. v. Allen, et al." on Justia Law

Appellant Andrew Murray was convicted by jury of malice murder and other crimes related to the shooting death of Paul Sampleton, Jr. Over the course of his motion-for-new-trial proceedings, Murray was appointed three different attorneys, each of whom he rejected. Representing himself at the last hearing on his motion for new trial, Murray purported to be a different person – “Billy Drew Bey” – who was acting as Murray’s attorney, prompting the trial court to enter an order either dismissing or denying Murray’s amended motion for new trial because “Bey” had not provided any support for the motion and “Murray” had failed to appear for the hearing. Murray appealed that order. The Georgia Supreme Court found that because the reasons given by the trial court were not proper grounds for dismissing or denying Murray’s amended motion for new trial, judgment was vacated and the case remanded for the court to consider the merits of Murray’s motion. View "Murray v. Georgia" on Justia Law

Jammie Rashad Davis appealed his convictions for murder and other crimes stemming from the 2018 shooting death of Latravius Burks. Davis argued: (1) the evidence was insufficient to support his convictions because evidence showed that he acted in self-defense; and (2) the trial court plainly erred in failing to instruct the jury on voluntary manslaughter. The Georgia Supreme Court concluded: (1) Davis’s sufficiency claim failed because the jury did not have to believe Davis’s self-serving testimony that he was defending himself. And (2) his claim of plain instructional error fails because the victim’s touching of Davis’s daughter’s lips was "not the kind of provocation that would have obviously required a voluntary manslaughter instruction." View "Davis v. Georgia" on Justia Law

The State appealed the grant of habeas relief to Aaron Houston, who pleaded guilty to three misdemeanor DUI counts. The habeas court vacated the convictions entered on those pleas on grounds that the pleas were tendered without the assistance of counsel and without Houston being advised of his right to counsel, and that Houston did not knowingly and voluntarily waive his right to counsel. The State argued to the Georgia Supreme Court that the habeas court erred because Houston did not produce sufficient evidence that his waiver of counsel was not knowing and voluntary. Because the habeas court did not clearly err in concluding that Houston was not advised of his right to counsel at the plea hearing, thereby precluding an express waiver of that right, the Supreme Court affirmed. View "Georgia v. Houston" on Justia Law

Tevision Troy appealed his convictions for the 2016 murder of Tony Saffo and a firearm offense. Troy argued only that the trial court erred in admitting evidence that he committed an aggravated assault in 1998 with the same gun that was used to kill Saffo. He contended admitting this evidence violated OCGA sections 24-4-404 (b) (“Rule 404 (b)”) and 24-4-403 (“Rule 403”). But the Georgia Supreme Court determined it did not need to reach the merits of Troy’s contentions, as the evidence’s admission was harmless even if erroneous. View "Troy v. Georgia" on Justia Law

Gai Spann filed suit against Rashida Davis and Kyra Dixon, administrators of the City of Atlanta Municipal Court (“the Clerks”), alleging that she was wrongfully arrested and detained as a result of the Clerks’ failure to withdraw a failure-to-appear warrant after it had been cancelled by a municipal court. The Clerks raised sovereign immunity and official immunity as defenses in a motion to dismiss, but the trial court instead sua sponte raised and granted the motion based on quasi-judicial immunity, with no prior notice to the parties. The Court of Appeals affirmed. The Georgia Supreme Court granted certiorari to review this case, and held the Court of Appeals erred in concluding the trial court was correct to rule sua sponte on the issue of quasi- judicial immunity, even though the defendants did not raise quasi-judicial immunity in the motion to dismiss or the answer. The appellate court's judgment was reversed and the matter remanded to the trial court for further proceedings. View "Spann v. Davis, et al." on Justia Law

Miguel Angel Garcia-Martinez was convicted of malice murder, four counts of aggravated assault, and four counts of possession of a firearm during the commission of a felony in connection with the 2018 shooting death of his friend and former roommate, Daniel Antonio-Lopez, and the aggravated assaults of Antonio-Lopez, Juan Carlos Mondragon, Saul Roman-Pintado, and Francisco Lopez. The trial court denied Garcia-Martinez’s motion for new trial, and he appealed, using as his sole enumeration of error the sufficiency of the evidence to support his convictions. Finding the evidence sufficient, the Georgia Supreme Court affirmed. View "Garcia-Martinez v. Georgia" on Justia Law

Rebecca Schoicket was granted an out-of-time appeal to appeal the judgment of conviction entered on her guilty plea. In addition to challenging her sentence on one count, she argued the out-of-time appeal she was granted meant that the trial court should have granted her motion for leave to file an otherwise untimely motion to withdraw her guilty plea. Schoicket argued that Collier v. Georgia, 834 SE2d 769 (2019), recognized that it would be a “logical extension” of Georgia case law to permit the filing of such a motion, because the Georgia Supreme Court has stated that the grant of an out-of-time appeal started the post-conviction process “anew.” The Supreme Court determined Schoicket was correct in that appraisal of Georgia case law, but the Court declined to extend it to afford her the relief she sought. "Allowing such a grant to then permit the movant to file a motion to withdraw a guilty plea would be an unwarranted windfall with potentially profound consequences for our criminal justice system." Accordingly, the Court affirmed the trial court's denials of Schoicket's motion for leave to pursue such relief. However, because the Court agreed with Schoicket that the sentencing court erred in sentencing as to one count, that count was vacated and remanded for resentencing. View "Schoicket v. Georgia" on Justia Law

Appellant Lil’Che Stafford was found guilty by jury of felony murder and first-degree burglary in connection with the death of Jose Greer. On appeal, Appellant argued: (1) evidence of an earlier burglary and armed robbery was improperly admitted at trial; (2) a testifying detective inappropriately opined that Appellant was involved in an additional prior robbery; (3) trial counsel was ineffective for failing to request a jury instruction on intervening or unforeseen cause of death; and (4) the detective’s testimony regarding the custodial statements of a co-conspirator was improperly admitted because it was inadmissible hearsay and trial counsel was ineffective for failing to object to its admission based on the Confrontation Clause. The Georgia Supreme Court concluded there was no reversible error, and affirmed. View "Stafford v. Georgia" on Justia Law