Justia Criminal Law Opinion Summaries

Appellants Khamone Luangkhot, Isaac Saleumsy, and Santisouk Phommachanh, along with approximately 34 others, were indicted in connection with an alleged ecstacy trafficking ring. The indictments resulted from a multi-jurisdictional investigation led by the Atlanta High Intensity Drug Trafficking Area (HIDTA) task force and conducted in collaboration with state prosecutors. As part of the investigation, the Gwinnett County District Attorney obtained a series of investigative warrants authorizing the interception of telephone conversations from 18 different telephone lines. Prior to trial, Appellants moved to suppress the evidence investigators had obtained through these wiretaps, contending that the Gwinnett court lacked jurisdiction to issue the warrants. The motions were denied, and, on interlocutory appeal, the Court of Appeals affirmed. The Supreme Court granted certiorari to determine whether the Court of Appeals properly construed the Georgia wiretap statute as authorizing superior courts to issue wiretap warrants that are effective outside their judicial circuits. Having reviewed the applicable law, the Court concluded that superior courts did not possess the authority to issue wiretap warrants for interceptions conducted outside the boundaries of their respective judicial circuits. Accordingly, the Gwinnett County Superior Court did not have the authority to issue the warrants in this case. View "Luangkhot v. Georgia" on Justia Law

Appellant Solomon Hester was convicted of malice murder, two counts of cruelty to a child, and possession of a firearm during the commission of a felony in connection with the shooting death of Allison Brownell. He appealed the denial of his motion for new trial, asserting that the State violated "Brady v. Maryland," (373 U. S. 83 (1963)) by failing to disclose the results of two toxicology tests. Finding no error, the Supreme Court affirmed. View "Hester v. Georgia" on Justia Law

The issue before the Supreme Court in this case concerned who was legally authorized to select the drug or drugs to be used in executions in Georgia and how that choice may be made-- an issue which the Court felt impacted the management of prisons and inmates in Georgia: "this case could also affect the remaining myriad of management decisions made throughout Georgia’s prison system, and . . . when those decisions must be made directly by the Board of Corrections in its policymaking role versus when they may by left to the statutorily-granted management prerogatives of the Commissioner of Corrections and the Department of Corrections that he manages." Warren Lee Hill was convicted of murdering a fellow inmate in the Lee County Correctional Institute by beating the victim with a board embedded with nails. Hill received the death sentence, and the Supreme Court affirmed. Hill was unsuccessful in his state and federal habeas proceedings. The execution was originally scheduled for July 18, 2012, but it was rescheduled for July 23, 2012. The change in the specific execution date was announced by the Department of Corrections at approximately the same time that the Department of Corrections announced that it was changing from a three-drug execution procedure to a one-drug procedure. In response to the announcement of the new execution procedure, Hill filed a complaint against the Board of Corrections, the Department of Corrections, and the Commissioner of Corrections, alleging that the defendants failed to comply with the requirements of the Administrative Procedure Act in adopting Georgia’s new execution procedure, and he sought a declaratory judgment, an injunction, a stay of execution, and a writ of mandamus. The Superior Court granted the defendants’ motion to dismiss Hill’s complaint on the ground that the Administrative Procedure Act did not apply to the new execution procedure, and the Supreme Court granted Hill’s application for discretionary appeal and his motion for a stay of his scheduled execution. But upon review of the applicable statutory authority, the Supreme Court affirmed that dismissal. View "Hill v. Owens" on Justia Law

In 2010, when appellee Joshua Johnson was 15 years old, he was arrested for the alleged murder of his grandmother. He was held in a youth detention center for ten days when he was released on bond with conditions that included home confinement (at his cousin’s house) and electronic monitoring. More than seven months later, appellee was indicted for murder. Appellee filed a motion asking the superior court to transfer his case to the juvenile court. He claimed that both his time in the youth detention center and on bond under the home confinement and electronic monitoring program constituted "detention," and because he was not indicted within 180 days of being so detained, he argued he was entitled to have his indictment dismissed and his case transferred to the juvenile court. The trial court denied the motion to dismiss, but granted motion to transfer the case to the juvenile court, ruling that the home confinement and electronic monitoring program qualified as detention. The State then filed this direct appeal. Having determined that the State was not authorized to bring this appeal, the Supreme Court concluded that it lacked jurisdiction to consider its merits and therefore expressed no opinion as to the trial court’s transfer order. View "Georgia v. Johnson" on Justia Law

In December 2007, Bobby Buckner was indicted for the kidnapping, molestation, and murder of 12-year-old Ashleigh Moore. Four years later, Buckner had not been brought to trial, so he filed a motion to dismiss his indictment, arguing that he had been denied his constitutional right to a speedy trial. Following a hearing, the trial court concluded that Buckner had indeed been denied his right to a speedy trial, and it dismissed the indictment. The State appealed the dismissal, contending that the trial court misapplied the principles set out in "Barker v. Wingo," (407 U. S. 514 (1972)), and "Doggett v. United States," (505 U. S. 647 (1992)). Upon review, the Supreme Court could not say that the trial court clearly erred in its assessment of the relevant facts, and "[could not] say that its ultimate conclusion, which appears reasoned and reasonable, amounts to an abuse of discretion. Accordingly, we must affirm the judgment below." View "Georgia v. Buckner" on Justia Law

Roddicus Butler was tried by jury and convicted of the murder of two-year-old Jamira Washington. Following the denial of his motion for new trial, Butler appealed, contending that the evidence was insufficient to sustain his conviction, that the trial court erred when it denied his motion to suppress certain statements that he gave to law enforcement, and that he was denied the effective assistance of counsel at trial. Upon our review of the briefs and record, the Supreme Court found no error and affirmed. View "Butler v. Georgia" on Justia Law

Appellant Sajid Fitzgerald Leslie was convicted of murder and arson in connection with the death of his former girlfriend Lori Hastings. He raised several issues on appeal, arguing: (1) the evidence presented at trial was insufficient to support his conviction; (2) the trial court erred in admitting certain character evidence and other testimony; (3) the trial court erred in failing to exclude Appellant's statements to the police on grounds that he was not given Miranda warnings; (4) he received ineffective assistance of counsel. Finding Appellant's arguments were without merit, the Supreme Court affirmed Appellant's conviction. View "Leslie v. Georgia" on Justia Law

Appellant Michael Reddings was convicted of murder, aggravated assault, and two weapons possession counts in connection with the 2009 stabbing death of Daisy Pearl Brown. Appellant appealed the denial of his motion for new trial, contending that the trial court committed reversible error by failing to merge the aggravated assault conviction with the murder conviction and by denying his motion for change of venue. Upon review, the Supreme Court agreed that the failure to merge was error, and therefore vacated his convictions for aggravated assault and the related weapons possession count. In all other respects, the Court affirmed the trial court’s judgment. View "Reddings v. Georgia" on Justia Law

Appellant Michael Kidd appealed his convictions for murder and possession of a firearm during the commission of a crime stemming from the shooting death of Ronald Davenport. Finding no error, the Supreme Court affirmed. View "Kidd v. Georgia " on Justia Law

Craig Heidt was tried by jury and convicted of the murders of his father and brother, an aggravated assault and aggravated battery upon his mother, burglary, attempt to commit arson in the first degree, and three counts of possession of a firearm during the commission of a felony. He appealed, contending that the evidence was insufficient to sustain his convictions and that the trial court erred when it disqualified one of his lawyers for a conflict of interest, denied his motion to disqualify the trial judge, denied his motion to change venue, attempted to rehabilitate prospective jurors who already had formed an opinion of his guilt, admitted certain evidence of his prior difficulties with his brother, and rejected his "Brady" claim. Finding no error, the Supreme Court affirmed. View "Heidt v. Georgia" on Justia Law