Justia Georgia Supreme Court Opinion Summaries
Logan v. Georgia
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
Posted in:
Constitutional Law, Criminal Law
Willerson v. Georgia
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
Posted in:
Constitutional Law, Criminal Law
Nelson v. Georgia
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
Posted in:
Constitutional Law, Criminal Law
Baker v. Georgia
Nathaniel Baker was convicted by jury of felony murder and other offenses in connection with crimes committed against Craigory Burch, Jr., Jasmine Hendricks, and C.B., a minor child. On appeal, Baker argued the evidence presented at trial was insufficient to support his convictions and that the trial court erred by allowing the State to present evidence of criminal gang activity. Finding no reversible error, the Georgia Supreme Court affirmed. View "Baker v. Georgia" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Walker v. Georgia
Appellant Quintavious Walker was convicted of the murder of Jaquille Thomas and Angelique Bowman. In his one issue raised on appeal, he contended the trial court erred by admitting into evidence at his trial incriminating statements that he made after he allegedly invoked his Fifth Amendment right to remain silent during a custodial interview with the police. The Georgia Supreme Court found Appellant’s purported invocations were not unambiguous and unequivocal and not clearly erroneous. Therefore, the trial court did not commit plain error by admitting the statements. View "Walker v. Georgia" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Woods v. Georgia
In 2013, Alexander Woods III was convicted by jury of five counts of malice murder and given five consecutive life sentences in connection with the 2004 shooting deaths of four members of the Resendez family and their housekeeper. Woods’ motion for new trial was denied, and he appealed, raising nine alleged instances of ineffective assistance of trial counsel. After review of the record, the Georgia Supreme Court vacated the trial court’s order denying Woods’ motion for new trial, and remanded the case for the trial court to rule in the first instance on the question of deficiency of trial counsel and related evidentiary issues. View "Woods v. Georgia" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Sims v. Georgia
Dion Sims appealed after a jury convicted him of malice murder and other crimes in connection with the 2001 shooting death of Alan Watson. On appeal, Sims argued: (1) the evidence presented at trial was insufficient to support his conviction; (2) the State failed to prove venue; and (3) his trial counsel provided constitutionally ineffective assistance by failing to file a plea in bar with respect to two counts of the indictment. After review, the Georgia Supreme Court determined Sims’ contentions lacked merit and affirmed his convictions. View "Sims v. Georgia" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Smith v. Long Cty. Bd. of Elections & Registration, et al.
Appellant Bobby Smith ran against Teresa Odum for the office of Probate Judge of Long County, Georgia on June 9, 2020. Following Odum’s victory, Smith filed a petition to contest the Election results, alleging there were: (1) irregularities committed by election officials; (2) illegal votes cast in the election; and (3) wrongfully rejected votes (collectively “irregularities”). After a three-day bench trial, the trial court concluded that the evidence was insufficient to cast doubt on the results of the Election and denied the petition. Smith appealed, asserting in four related enumerations of error that the trial court erred by not ordering a new election. After review, the Georgia Supreme Court determined seven ballots should have been rejected: “Those seven ballots are not sufficient to place the results of the Election in doubt given the nine-vote margin of victory in this case.” Finding no error in the trial court’s denial of Smith’s petition to contest the Election, the Supreme Court affirmed the trial court’s judgment. View "Smith v. Long Cty. Bd. of Elections & Registration, et al." on Justia Law
Posted in:
Election Law
Orr v. Georgia
Keilan Orr was convicted by jury of felony murder and possession of a firearm during the commission of a felony in connection with the shooting death of Lamario Majors. On appeal, Orr argued the evidence presented at trial was insufficient to support his convictions, and that the trial court erred by failing to charge the jury on voluntary manslaughter. After review of the trial court record, the Georgia Supreme Court found no reversible error and affirmed Orr’s convictions. View "Orr v. Georgia" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Mobuary v. Georgia
The Georgia Supreme Court granted pro se petitioner Jason Mobuary’s petition for certiorari review. In 2003, petitioner pled guilty to enticing a child for indecent purposes. In 2018, he moved the trial court for an out-of-time appeal and motion for appointment of counsel. The trial court denied both motions in late 2019. Mobuary filed a notice of appeal of the trial court’s rulings. He mailed his notice of appeal on May 12, 2020; the trial court received the notice of appeal on May 22, 2020, and stamped it “filed” and docketed it on May 26, 2020. On June 16, 2020, in its Case No. A20A1922, the Court of Appeals dismissed the appeal for lack of jurisdiction on the basis that, “[b]ecause Mobuary’s notice of appeal was filed 167 days after the order he seeks to appeal, it is untimely[.]” The record showed, however, that Mobuary initiated the appellate process in the time allowed, by filing on January 8, 2020, a request for an extension of time from the Supreme Court in which to file an application for a discretionary appeal. The Supreme Court granted an extension through February 10, 2020, and Mobuary filed a discretionary application by the extended deadline. Because the application involved a non-murder criminal offense, and did not appeal to raise any issues that would otherwise invoke the Supreme Court’s jurisdiction, the case was transferred to the Court of Appeals, docketed as Case No. A20D0344. The Court of Appeals determined Mobuary’s case could proceed via direct appeal, and on May 8, 2020, granted Mobuary’s application of discretionary appeal. The May 2020 order was entered when certain filing requirements were tolled by the Chief Justice in response to the global COVID-19 pandemic. In sum, the conclusion that Mobuary’s notice of appeal was untimely was made in error, and the judgment was reversed. View "Mobuary v. Georgia" on Justia Law
Posted in:
Constitutional Law, Criminal Law