Justia Georgia Supreme Court Opinion Summaries

Addonis Rhodes was convicted of malice murder and other offenses related to the shooting death of Vernard Mays. The incident occurred when Rhodes, along with several co-indictees who were members of the “10-12” street gang and the Crips, went to Mays’s mother’s home searching for a missing gun. Believing someone in the house had taken the gun, Rhodes and his associates confronted Mays at the back door. After a brief exchange, Rhodes, prompted by a signal from another co-indictee, shot Mays, and others also fired. Mays died from a gunshot wound to his leg. In the days following the shooting, Rhodes attempted to kill a co-indictee, Curtis Jackson, Jr., whom he suspected of implicating him in the crime.A Bibb County grand jury indicted Rhodes and four others for malice murder, felony murder, and violation of the Street Gang Terrorism and Prevention Act. Three co-indictees pleaded guilty and testified against Rhodes and Jackson, who were tried together. The Superior Court of Bibb County jury found both guilty on all charges. Rhodes was sentenced to life in prison for malice murder, with other counts vacated. After his conviction, Rhodes filed a motion for new trial, which was denied.On appeal to the Supreme Court of Georgia, Rhodes argued that the trial court erred in admitting a Facebook post he made shortly after the murder and that his trial counsel was ineffective in several respects. The Supreme Court of Georgia held that the Facebook post was relevant and its probative value was not substantially outweighed by unfair prejudice. The court also found that Rhodes failed to show his counsel was ineffective for not moving to exclude gang evidence, not seeking a bifurcated trial, not moving to exclude evidence of his plot against Jackson, or failing to convey a plea offer. The court affirmed the judgment. View "RHODES v. THE STATE" on Justia Law

The case concerns a woman who was convicted of felony murder and other offenses after fatally shooting her husband during a domestic dispute. The incident occurred after an argument about alleged infidelity, with both parties having a history of mutual violence. On the day of the shooting, the woman and her son waited in a car while her husband prepared to confront the alleged third party. After a delay, she re-entered the house, an argument ensued, and she shot her husband, who later died. The woman claimed the shooting was accidental or in self-defense, citing a history of abuse and presenting expert testimony on battered person syndrome. The prosecution, however, presented evidence that contradicted her account, including testimony that she had loaded the gun earlier and that she had previously threatened or been violent toward her husband.The Superior Court of Jackson County held a jury trial, where the woman was acquitted of malice murder but convicted of felony murder, aggravated assault, cruelty to children in the second degree, and firearm offenses. She was sentenced to life in prison and other concurrent and consecutive terms. After her conviction, she filed a motion for a new trial, arguing that the verdict was against the weight of the evidence and that the court failed to properly consider her battered person syndrome defense and her motion for immunity. The trial court denied her motion.The Supreme Court of Georgia reviewed the case and affirmed the convictions. The Court held that the evidence was constitutionally sufficient to support the verdicts, as the jury was entitled to disbelieve the defendant’s claims of accident or self-defense. The Court also found that the trial court properly exercised its discretion in denying a new trial and correctly determined that the defendant had not established entitlement to immunity by a preponderance of the evidence. View "WHISNANT v. THE STATE" on Justia Law

On July 30, 2008, Barry Bullard was shot and killed in Tift County, Georgia. The incident followed a series of disputes between Bullard and three men: Jeremy Reynolds, Neddrick Green, and Allen Williams. Tensions had escalated after Williams believed Bullard had stolen a gun from him, leading to repeated confrontations. On the night of the shooting, witnesses observed Williams, Green, and Reynolds driving by Bullard’s home, after which a confrontation ensued in Bullard’s yard. Testimony at trial indicated that after a brief altercation, Reynolds approached Bullard and shot him in the head at close range. Multiple eyewitnesses identified Reynolds as the shooter, and physical evidence, including fingerprints and a recovered firearm, further linked him to the crime.Following the incident, a Tift County grand jury indicted Reynolds, Green, and Williams for malice murder, with Reynolds also facing a charge of possession of cocaine. Williams was tried separately and convicted, while Reynolds and Green were jointly tried and found guilty by a jury in November 2010. Reynolds was sentenced to life in prison without parole for malice murder and received a concurrent 30-year sentence for possession of cocaine. After his conviction, Reynolds filed a motion for a new trial, which was amended and ultimately denied by the trial court in August 2023.The Supreme Court of Georgia reviewed Reynolds’s appeal, in which he argued that the evidence was constitutionally insufficient to support his malice murder conviction. The Court applied the standard from Jackson v. Virginia, considering whether a rational trier of fact could have found Reynolds guilty beyond a reasonable doubt. The Court held that the evidence, including eyewitness testimony and corroborating physical evidence, was sufficient to sustain the conviction. The judgment of the trial court was affirmed. View "REYNOLDS v. THE STATE" on Justia Law

Deonte Kitchens was convicted of malice murder and other crimes related to the shooting death of Alveno Culver. Kitchens was indicted in November 2015 and tried alone in September 2016, where the jury found him guilty on all counts. He was sentenced to life in prison without parole for malice murder, along with additional consecutive and concurrent sentences for other charges. Kitchens filed a motion for a new trial, claiming, among other things, that his constitutional right to a speedy trial was violated.The trial court denied Kitchens's motion for a new trial, rejecting his speedy-trial claim. Kitchens appealed, arguing that the trial court made a clearly erroneous finding about a material fact and misapplied the law in several significant ways. The trial court found that the delay was due to the complexity of the case and the State's ongoing investigation, and it did not weigh this factor heavily against the State. The court also found that Kitchens never invoked his right to a speedy trial, which was a clearly erroneous finding since Kitchens had filed a constitutional speedy trial demand in August 2014.The Supreme Court of Georgia reviewed the case and found that the trial court made several errors in its analysis. The trial court failed to calculate the length of the delay correctly, conflated the analyses of presumptive prejudice and the length of the delay, and did not consider whether the delay was uncommonly long. The Supreme Court vacated the trial court's order denying Kitchens's motion for a new trial and remanded the case for the trial court to properly address the speedy-trial claim, considering the correct facts and legal analysis. View "KITCHENS v. THE STATE" on Justia Law

Gregory M. Hilton was convicted of malice murder and other crimes after he shot and killed his next-door neighbor, Tommy Allen, on January 29, 2018. Hilton was indicted on charges of malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. After a series of competency evaluations, Hilton was found competent to stand trial. During the trial, evidence showed that Hilton shot Allen as he was getting into his car. Hilton confessed to the murder and explained that he was in a dire financial situation and felt hopeless. He claimed that Allen had violated him, although he could not specify how.The Chatham County trial court found Hilton guilty on all counts, sentencing him to life in prison for malice murder and an additional five years for the firearm offense. Hilton's motion for a new trial was denied. He appealed, arguing that the trial court erred by not instructing the jury on voluntary manslaughter.The Supreme Court of Georgia reviewed the case. Hilton contended that his statements about feeling threatened by Allen warranted a voluntary manslaughter instruction. The court was skeptical that Hilton's vague statements constituted sufficient evidence of provocation. However, even if the trial court erred in not giving the instruction, the Supreme Court concluded that any error was harmless. The evidence strongly indicated that Hilton acted with malice aforethought due to his financial desperation, and the jury would likely have rejected a voluntary manslaughter claim. Therefore, the Supreme Court of Georgia affirmed Hilton's convictions. View "HILTON v. THE STATE" on Justia Law

Yaquan Chapman and Jordan Watson were convicted for the shooting death of William Trawick and the assault of Aubrey Stansill and Griffin Cleveland. On February 16, 2021, Chapman, Watson, Calvin Rozier, and Carey Williams planned to rob Trawick during a marijuana purchase. They recruited Christian Miles to drive them to Trawick’s home. Watson carried an AR-15, while Rozier and Chapman had handguns. After spending time inside Trawick’s home, Rozier signaled the start of the robbery. Williams retrieved Watson from the car, and the group began shooting, resulting in Trawick’s death and injuries to Stansill and Cleveland. The group fled but returned to retrieve personal items, leading to more gunfire. Chapman was injured, and the group eventually dispersed after seeking medical help for Chapman.A Butts County grand jury indicted Chapman, Watson, Rozier, and Williams. Williams’s case was severed, and he testified for the State. Following a jury trial, Chapman and Watson were found guilty on all counts and sentenced to life in prison without parole for malice murder, plus additional years for aggravated assault. Both filed motions for a new trial, which were denied by the trial court.The Supreme Court of Georgia reviewed the case. Chapman argued trial errors and ineffective assistance of counsel, while Watson contended insufficient evidence and ineffective assistance of counsel. The court found sufficient evidence to support the convictions, noting the testimonies and physical evidence linking both defendants to the crimes. The court also held that the trial court did not abuse its discretion in its rulings and that the defendants failed to demonstrate prejudice from their counsel’s actions. Consequently, the Supreme Court of Georgia affirmed the convictions and sentences of both Chapman and Watson. View "CHAPMAN v. THE STATE" on Justia Law

Xavier Adams, Jr. was convicted of felony murder and other crimes related to the shooting death of Sean Peterson. The incident occurred on September 5, 2017, when Peterson, Adams, and Adams's then-wife, Destinee Pannell, were roommates. An argument over rent escalated, leading to both men retrieving firearms. During a struggle, Peterson was shot and killed. Adams attempted to cover up the incident by creating an alibi and preventing Pannell from contacting the police. Adams was indicted on multiple charges, including malice murder and felony murder, and was found guilty by a jury in June 2019.The trial court sentenced Adams to life in prison without parole for felony murder predicated on possession of a firearm by a convicted felon. Adams filed a motion for a new trial, which was denied after an evidentiary hearing. He then appealed to the Supreme Court of Georgia, arguing several points, including the trial court's failure to vacate his felony murder conviction under the modified merger rule, mutually exclusive verdicts, improper comments on evidence, and errors in jury instructions.The Supreme Court of Georgia affirmed the trial court's decision. The court held that the modified merger rule did not apply because Adams's possession of the firearm was independent of the killing. The court also found that the verdicts were not mutually exclusive, as felony murder predicated on possession of a firearm does not require intent to kill. Additionally, the court concluded that the trial court did not improperly comment on the evidence, did not commit plain error in its jury instructions, and that Adams had affirmatively waived any claim of error regarding the trial court's response to a jury note. View "ADAMS v. THE STATE" on Justia Law

Steven Alford Jacobs was convicted of malice murder and other crimes related to the shooting death of Curtis Pitts. The incident occurred on September 21, 2018, and Jacobs was indicted on multiple charges, including malice murder, felony murder, aggravated assault, armed robbery, and possession of a firearm during the commission of a felony. The jury found Jacobs guilty on all counts, and he was sentenced to life in prison without the possibility of parole for malice murder, among other sentences for the additional charges.Jacobs filed a motion for a new trial, which was denied by the trial court. He appealed, arguing that his constitutional right to be present during a critical phase of the trial was violated when the jury viewed a vehicle connected to the charges without him being present. During the trial, the jury was allowed to view the van involved in the case, and Jacobs's defense objected, questioning whether the van was in the same condition as it was in 2018. The trial court allowed the viewing, and Jacobs's attorneys testified that they had discussed the right to be present with Jacobs, who chose not to attend the viewing.The Supreme Court of Georgia reviewed the case and affirmed the trial court's decision. The court held that even if Jacobs had a right to be present during the jury's viewing of the van, the evidence supported the trial court's conclusion that Jacobs waived that right. The court found that Jacobs's attorneys had informed him of his right to be present, and Jacobs had explicitly declined to attend the viewing. Therefore, the trial court's finding that Jacobs waived his right to be present was not clearly erroneous, and Jacobs was not entitled to a new trial based on his absence during the jury's viewing of the van. View "JACOBS v. THE STATE" on Justia Law

Aaron Lewis was indicted in Gwinnett County in 2021 for the felony murders of Dieterick Stephen Duncker and Alexandria Thompson, along with other related crimes. The indictment alleged that Lewis sold and distributed fentanyl-laced heroin to Duncker and Thompson, causing their deaths in Gwinnett County. Lewis filed a motion to dismiss the felony-murder counts, arguing that venue was improper in Gwinnett County since the sales occurred in DeKalb County.The trial court denied Lewis's amended motion to dismiss, reasoning that the ingestion of the narcotics and the resulting deaths in Gwinnett County made venue proper there. The court granted a certificate of immediate review, and Lewis's interlocutory application to review the trial court's ruling on venue was accepted.The Supreme Court of Georgia reviewed the case and vacated the trial court's order denying Lewis's amended motion to dismiss. The Supreme Court found that the trial court had improperly relied on the case Eubanks v. State, which dealt with the sufficiency of evidence for a felony murder conviction, not venue. The Supreme Court clarified that the relevant question for venue is where the cause of death was inflicted, as per OCGA § 17-2-2 (c). The case was remanded for further proceedings consistent with this opinion. View "Lewis v. State" on Justia Law

Allen Turner died from surgical complications, leading his daughter, Norkesia Turner, to sue Drs. William Thompson and Heather Nolan, and their employer, the Medical Center of Central Georgia, Inc. (MCCG), for medical malpractice and wrongful death. The jury awarded Turner approximately $7.2 million in noneconomic damages for wrongful death. MCCG moved to reduce this award to the statutory cap of $350,000 under OCGA § 51-13-1 (b) and (c), but the trial court denied the motion, citing the Georgia Supreme Court's decision in Atlanta Oculoplastic Surgery, P.C. v. Nestlehutt, which found such caps unconstitutional.MCCG appealed to the Court of Appeals, which affirmed the trial court's decision, reasoning that the Nestlehutt decision foreclosed MCCG's argument. The Court of Appeals held that the $7.2 million award did not need to be reduced to the statutory cap. MCCG then petitioned the Supreme Court of Georgia for a writ of certiorari, which was granted to address whether the Court of Appeals properly applied the precedent regarding the constitutional right to trial by jury.The Supreme Court of Georgia did not decide whether the application of OCGA § 51-13-1’s caps to the $7.2 million award would violate Turner’s constitutional right to a jury trial. Instead, it found that the lower courts had not applied the correct analytical framework from Nestlehutt to the wrongful death claim. The Supreme Court clarified that the holding in Nestlehutt was specific to medical malpractice claims and did not control the issue in this case. Consequently, the Supreme Court vacated the decision of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "THE MEDICAL CENTER OF CENTRAL GEORGIA, INC. v. TURNER" on Justia Law