Justia Georgia Supreme Court Opinion Summaries

Brantley Washington and his co-defendants, Chrishon Siders and Haleem Graham, were convicted of malice murder, first degree burglary, and other crimes in connection with the 2016 shooting death of Seine Jackson. Washington appealed, arguing the trial court erred in admitting hotel surveillance videos from the day before and the day of the crimes, along with the opinion testimony of two detectives describing the surveillance videos and a dashcam video recording of a traffic stop taken on the night of the crimes. Washington also claimed he received ineffective assistance of counsel when his trial counsel failed to object to that evidence. Finding no reversible error, the Georgia Supreme Court affirmed Washington's convictions. View "Washington v. Georgia" on Justia Law

A jury found Mustafa Mahdi guilty but mentally ill of the 2014 malice murder of John Quincy III and guilty of possession of a knife during the commission of a felony. Appealing pro se appeal, Mahdi broadly claimed the trial court, as well as his trial and appellate counsel, violated his constitutional rights. After review, the Georgia Supreme Court discerned from these claims that Mahdi was arguing: (1) the trial court violated his due process rights by allowing his trial attorneys to present an insanity defense against his wishes; (2) he received ineffective assistance of trial and motion-for-new trial counsel; and (3) his trial and motion counsel violated his right to conflict-free representation. Finding no reversible error, the Supreme Court affirmed Mahdi's convictions. View "Mahdi v. Georgia" on Justia Law

Darius Dunn appealed his convictions for malice murder and other charges in connection with the 2015 shooting death of Anthony Tavarez. Dunn claimed on appeal that the evidence at trial was insufficient to support his conviction for a violation of the Georgia Street Gang Terrorism and Prevention Act. He also argued the trial court abused its discretion in admitting alleged bad character evidence and allegedly irrelevant and prejudicial video evidence. Finally, Dunn contended he received constitutionally ineffective assistance of counsel because his trial counsel did not seek to redact the State’s exhibits to exclude allegedly irrelevant and prejudicial bad character evidence. Finding no reversible error, the Georgia Supreme Court affirmed. View "Dunn v. Georgia" on Justia Law

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