Justia Criminal Law Opinion Summaries

Appellant Shabuoy Pitchford was convicted of murder, burglary, armed robbery, and related offenses in connection with the September 2006 shooting death of Rickey Greene. Appellant appealed the denial of his motion for new trial, contending certain evidence should have been suppressed, other evidence was improperly admitted, the evidence on the armed robbery count was insufficient, and the jury instructions were erroneous in certain respects. Finding no error, the Supreme Court affirmed. View "Pitchford v. Georgia" on Justia Law

Tommy Tyrone Griffin was convicted of felony murder and conspiracy to commit trafficking in cocaine in connection with a fatal shooting in 2010. Griffin appealed the denial of his motion for new trial, challenged the sufficiency of the evidence and the trial court's instructions to the jury. After review, the Supreme Court found that the State failed to adduce any evidence on an essential element of the drug conspiracy charge and therefore conviction for conspiracy to commit trafficking in cocaine was reversed. Because the felony murder conviction was predicated on the drug conspiracy offense, that conviction was also reversed. View "Griffin v. Georgia" on Justia Law

Timothy Parody was granted habeas relief premised on a finding that he received ineffective assistance of trial counsel. The acting warden of Augusta State Medical Prison appealed. Finding that the habeas court's conclusion was factually and legally incorrect in granting relief, the Supreme Court reversed and remanded the case for further proceedings. View "Brown v. Parody" on Justia Law

Appellant Lincoln Quantavious Boykins was convicted of murder and other offenses in connection with the June 2008 shooting death of Quinton Denley. On appeal, Boykins challenged the sufficiency of the evidence presented against him at trial. Finding the evidence sufficient to support his conviction, the Supreme Court affirmed Boykins' conviction. View "Boykins v. Georgia" on Justia Law

Appellant Dennis Allaben was convicted of malice murder, felony murder, aggravated assault with intent to murder, battery, simple battery, and reckless conduct in connection with the strangulation death of his wife, Maureen. The felony murder verdict was vacated by operation of law, and the trial court entered a judgment of conviction only for malice murder, merging the remaining verdicts into that conviction. On appeal, Allaben contended that, among other things, the jury returned mutually exclusive verdicts. After its review, the Supreme Court concluded that the guilty verdict on reckless conduct was mutually exclusive of the remaining verdicts, therefore the Court reversed Allaben's conviction for malice murder, set aside all the guilty verdicts, and remanded the case for further proceedings. View "Allaben v. Georgia" on Justia Law

In 1993, Demarcus Sears was convicted of kidnapping with bodily injury and armed robbery in connection with the death of Gloria Wilbur, who was kidnapped and robbed of her automobile in Georgia, raped in Tennessee, and murdered in Kentucky. The jury recommended a death sentence for the kidnapping with bodily injury after finding multiple statutory aggravating circumstances, including that the kidnapping with bodily injury was committed while Sears was engaged in the commission of the capital felony of murder. After affirming each of his convictions and the life sentence for the armed robbery, the Supreme Court remanded the case for proceedings related to Sears' claim of jury misconduct at the sentencing phase. In 2000, Sears filed a petition for a writ of habeas corpus, alleging among other claims, that his trial counsel rendered ineffective assistance of counsel. In an order filed in early 2008, the habeas court denied Sears' petition, and the Supreme Court denied Sears' application for a certificate of probable cause to appeal upon concluding that it lacked “arguable merit.” However, in a per curiam opinion, the United States Supreme Court granted Sears' petition for a writ of certiorari and held that, with regard to Sears' ineffective assistance of trial counsel claim, the habeas court failed to conduct a proper prejudice analysis under "Strickland v. Washington," (466 U. S. 668 (1984)). The federal Supreme Court then vacated the Georgia Court's order denying Sears' application for a certificate of probable cause to appeal and remanded the case for further proceedings not inconsistent with its opinion. In 2011, after a new habeas judge was assigned to the case and after a hearing, the habeas court entered a new order which adopted the 2008 Order with regard to all of Sears' claims except for his ineffective assistance of counsel claim, once again denying him relief on those claims. With regard to the ineffective assistance claim, the habeas court concluded that, even if he could prove that trial counsel rendered deficient performance, Sears had failed to prove that he was constitutionally prejudiced as a result. The Georgia Supreme Court granted Sears' application for a certificate of probable cause to appeal from the 2011 Order. After review of the 2011 order, the Supreme Court affirmed the denial of Sears' habeas petition. View "Sears v. Humphrey" on Justia Law

A jury acquitted Christopher Roesser of malice murder, felony murder, and aggravated assault, but was unable to reach a verdict on the lesser included offense of voluntary manslaughter. When the State sought to retry Roesser for voluntary manslaughter, he filed a plea in bar asserting double jeopardy based on collateral estoppel. The trial court denied the plea, and the Court of Appeals affirmed. The Supreme Court concluded that the doctrine of collateral estoppel prohibited the State from retrying Roesser for voluntary manslaughter. Therefore, the Court reversed. View "Roesser v. Georgia" on Justia Law

The Warden sought review of the grant of habeas relief to appellee Ryan Smith. Appellee was convicted of malice murder and sentenced to life in prison in 2002. Appellee subsequently filed a petition for a writ of habeas corpus, alleging his trial/appellate counsel was ineffective for failing to challenge the State's proof of venue, allowing an un-redacted indictment to go out with the jury, and for failing to challenge the seating of an alternate juror. The habeas court granted appellee relief on all of his claims, set aside appellant's conviction and sentence, and remanded the case to the trial court. After its review, the Supreme Court disagreed with the habeas court's decision and reversed that decision in its entirety. View "O'Donnell v. Smith" on Justia Law

Grant Murphy Ensley appealed his convictions and sentences for the malice murder of his father, possession of a firearm during the commission of felonies, and the unlawful handling of an explosive device. Upon review, the Supreme Court affirmed the conviction but remanded for recalculation of Ensley's sentence. View "Ensley v. Georgia" on Justia Law

Appellant Darrell Crowder sought review of his convictions for murder and related crimes for the shooting death of his estranged wife Catcilia Crowder. On appeal, he challenged the sufficiency of the evidence presented against him at trial, and argued he received ineffective assistance of trial counsel. Finding that the evidence was sufficient to support his conviction, and that he did not make a showing he received ineffective assistance, the Supreme Court affirmed appellant's convictions. View "Crowder v. Georgia" on Justia Law