Justia Georgia Supreme Court Opinion Summaries

Appellant Gerrod Crawford was convicted of felony murder and other crimes related to the 2015 shooting death of Antonio McBride. On appeal, he contended the trial court should have granted his motion for a directed verdict of acquittal and that his trial counsel provided ineffective assistance by failing to make a timely objection to an improper statement made by the prosecutor during her closing argument. Finding no reversible error, the Georgia Supreme Court affirmed. View "Crawford v. Georgia" on Justia Law

Tonya Tidwell was convicted by jury of malice murder and aggravated battery in connection with the death of David Guice. On appeal, Tidwell claimed the trial court erred by failing to charge the jury on mutual combat and by failing to suppress evidence obtained during the post-incident search of the crime scene. Finding no reversible error, the Georgia Supreme Court affirmed Tidwell's conviction. View "Tidwell v. Georgia" on Justia Law

The Georgia Supreme Court granted certiorari to reconsider one of its holdings in Allstate Insurance Co. v. Klein, 422 SE2d 863 (1992). In Klein, the Court held that Georgia courts could exercise general personal jurisdiction over any out-of-state corporation that was “authorized to do or transact business in this state at the time a claim arises.” Although Klein’s general-jurisdiction holding was in tension with a recent line of United States Supreme Court cases addressing when state courts may exercise general personal jurisdiction over out-of-state corporations in a manner that accords with the due process requirements of the United States Constitution, the Georgia Court held Klein did not violate federal due process under Pennsylvania Fire Insurance Co. of Philadelphia v. Gold Issue Mining & Milling Co., 243 U. S. 93 (1917), a decision that the U.S. Supreme Court has not overruled. "Thus, we are not required to overrule Klein as a matter of binding federal constitutional law. We also decline to overrule Klein as a matter of statutory interpretation. Therefore, we affirm the Court of Appeals’ decision, which followed Klein." View "Cooper Tire & Rubber Co. v. McCall" on Justia Law

After Sally Madison Roberts was involved in a car accident with a vehicle owned by Unison Behavioral Health (a Georgia community service board), she filed suit against Unison. As required by the Georgia Tort Claims Act (“GTCA”), Roberts provided an ante litem notice listing, among other things, the nature of her loss. Unison moved to dismiss Roberts’s complaint for lack of subject matter jurisdiction, arguing that the description of her loss was insufficient. The trial court denied the motion to dismiss, but after Unison was granted an interlocutory appeal, the Court of Appeals reversed. The Georgia Supreme Court granted Roberts’s petition for certiorari to decide whether the Court of Appeals erred in determining that Roberts’s ante litem notice failed to meet the requirements of OCGA 50-21-26 (a) (5) (D). Because the Supreme Court concluded Roberts’s notice was sufficient, it reversed the Court of Appeals’ decision. View "Roberts v. Unison Behavioral Health" on Justia Law

Minnie Fountain, as guardian for her adult nephew, Leroy Wiggins, filed claims against Wiggins’s skilled nursing facility and its management: CL SNF, LLC d/b/a Clinch Healthcare Center (“CHC”); RWC Healthcare, LLC; PWW Healthcare, LLC; and Beacon Health Management, LLC (collectively, “Clinch”), after Wiggins allegedly was assaulted while in their care. Clinch moved to compel arbitration of the claims, which the trial court denied. The Court of Appeals affirmed the trial court’s ruling based on a determination that neither the letters of guardianship issued by the probate court nor the provisions of the Georgia Code pertaining to guardians of adult wards gave Fountain the authority to enter into a pre-dispute arbitration agreement on Wiggins’s behalf. The Georgia Supreme Court granted Clinch’s petition for certiorari and reversed the Court of Appeals in CL SNF, LLC v. Fountain, 843 SE2d 605 (2020), because it concluded that the Guardianship Code granted a guardian authority to enter into a binding pre-dispute arbitration agreement where the exercise of such power was reasonably necessary to provide adequately for the ward’s support, care, health, and welfare. View "CL SNF, LLC et al. v. Fountain" on Justia Law

Leon Williams was convicted by jury of malice murder, terroristic threats, and three counts of cruelty to children in connection with the drowning death of his ten-year-old autistic and special needs son, Kentae. Williams contended the evidence presented at trial was insufficient to support his convictions. He also argued that one of his three convictions for cruelty to children should have been vacated because it merged with his malice murder conviction. Finding no reversible error, the Georgia Supreme Court affirmed. View "Williams v. Georgia" on Justia Law

Appellant Brian Lewis was convicted by jury of malice murder and concealing the death of another in connection with the beating death of Ronald Redding. Appellant argued: the evidence presented at his trial was insufficient to support his murder conviction; the trial court erred by failing to charge the jury on voluntary manslaughter; he was denied constitutionally effective assistance of counsel; and that the cumulative effect of trial counsel’s errors prejudiced him. Finding no reversible error, the Georgia Supreme Court affirmed. View "Lewis v. Georgia" on Justia Law

Appellant Carl Logan challenged his 2017 convictions for malice murder and possession of a knife during the commission of a crime in connection with the 2012 stabbing and beating death of Anthony Olivet. Appellant’s sole enumeration of error was that the trial court violated his constitutional rights to confront his accusers by preventing him from playing for the jury certain audio-recorded statements that a prosecution witness made to law enforcement officers to impeach the witness on cross-examination. The Georgia Supreme Court determined the record did not support this claim. Accordingly, the Court affirmed the trial court. View "Logan v. Georgia" on Justia Law

Bryant Willerson was convicted of murder in connection with the 2011 beating death of William McClain. On appeal, Willerson contended the evidence presented at his trial was insufficient to find him guilty beyond a reasonable doubt of the crime of which he was convicted. He also argued his trial counsel rendered constitutionally ineffective assistance for failing to properly impeach a witness. Finding no reversible error, the Georgia Supreme Court affirmed. View "Willerson v. Georgia" on Justia Law

The Georgia Supreme Court granted Corey Nelson's application for interlocutory appeal of a trial court's denial of his motion to suppress evidence. At issue was evidence extracted from his cell phone and other electronic devices pursuant to search warrants. Nelson argued that the delay of more than two years between the date on which the electronic devices were seized pursuant to a search warrant for his residence, and the dates on which the devices were examined pursuant to subsequent search warrants for their contents, violated his Fourth Amendment rights. The Supreme Court found the evidence challenged here was extracted days after warrants issued in 2020. The only challenge Nelson offered to this evidence was the long delay between the 2017 seizure of the devices and the 2020 issuance of the warrants. The Court found his possessory interest in the devices was greatly diminished by the combination of his incarceration for the entire period of the delay and his failure to request the devices’ return. Thus, the Court concluded the trial court did not err in denying the motion to suppress. View "Nelson v. Georgia" on Justia Law