Justia Criminal Law Opinion Summaries

Antonio Wallace, convicted of felony murder in 2011, sought original autopsy photographs for his pending habeas case. He requested these photographs under the Open Records Act, but the District Attorney refused. Wallace then filed a motion in the superior court where he was convicted, arguing that his request fit within exceptions for "medical purposes" or "public interest" under OCGA § 45-16-27 (d).The trial court found Wallace's arguments unconvincing and denied his motion. Wallace was convicted in Ware County, and his conviction was affirmed by the Supreme Court of Georgia in 2020. In 2021, he filed a habeas corpus petition in Wheeler County. In 2024, he filed a motion for limited disclosure of original trial exhibits, specifically the autopsy photographs, to Dr. Jan Gorniak, citing the poor quality of the copies he had.The trial court held a hearing where Wallace's counsel argued that the photographs were necessary to establish ineffective assistance of counsel. The victim's sister opposed the disclosure. The trial court denied the motion, and Wallace appealed, raising the same arguments.The Supreme Court of Georgia reviewed the case and affirmed the trial court's decision. The court held that the disclosure of autopsy photographs was not for "medical purposes" as Wallace's intent was legal, not medical. Additionally, the court found that the disclosure was not "in the public interest" as the victim's family opposed it, and Wallace's arguments did not outweigh their privacy concerns. Thus, the District Attorney was not required to disclose the photographs. View "WALLACE v. THE STATE" on Justia Law

Tanaiveon Johnson was convicted of felony murder and other offenses related to a gang-related shootout in which his friend, Arraffi Williams, was killed. The incident occurred on September 13, 2017, and Johnson was indicted along with five others on September 19, 2018. Johnson faced multiple charges, including felony murder, aggravated assault, and firearm possession. During his trial in October 2021, Johnson was found guilty on all counts, and he was sentenced to life in prison plus a five-year probated sentence for one firearm count. Johnson's motion for a new trial was denied, leading to this appeal.The trial court allowed the State to reopen evidence during jury deliberations to introduce a jail call recording in which Johnson admitted to shooting back to protect the car during the incident. Johnson argued that this was an abuse of discretion, but the Supreme Court of Georgia found no abuse, noting that the State had discovered the call relatively quickly and that Johnson had taken steps to conceal it. The court also gave the defense time to prepare and present additional arguments.Johnson also claimed ineffective assistance of counsel, arguing that his trial counsel pressured him not to testify. The court found that counsel's advice was reasonable given Johnson's communication difficulties and that Johnson had not shown prejudice from not testifying. Johnson's proffered testimony was inconsistent and would not have likely changed the trial's outcome.Finally, Johnson argued that the trial court erred in its jury instructions regarding proximate cause. The Supreme Court of Georgia reviewed this claim for plain error and found that Johnson had not shown that the omission of a specific proximate cause instruction probably affected the trial's outcome. The court affirmed Johnson's convictions. View "JOHNSON v. THE STATE" on Justia Law

Kiwani Khalif Patterson was convicted of malice murder and other crimes related to the shooting death of Tarik Bentley. The crimes occurred on April 24, 2016, and Patterson was indicted on August 17, 2016. A jury found him guilty on all counts during a trial held from February 24 to 26, 2020. On March 5, 2020, the trial court sentenced Patterson to life in prison without the possibility of parole for malice murder and an additional 15-year sentence for possession of a firearm by a convicted felon. Patterson filed a timely motion for a new trial, which was denied on June 10, 2024.Patterson did not timely appeal the denial of his motion for a new trial. Instead, on August 27, 2024, he filed a notice of appeal and a motion for reconsideration and extension of time to file a notice of appeal. On August 29, 2024, the trial court set aside its previous order denying the motion for a new trial and re-entered the order. Patterson then filed a new notice of appeal on September 10, 2024.The Supreme Court of Georgia reviewed whether it had jurisdiction over the appeal, given the untimely notice of appeal. The court concluded that the trial court was divested of jurisdiction once the untimely notice of appeal was filed, rendering the trial court's subsequent orders void. Consequently, the Supreme Court of Georgia vacated the judgment, dismissed the appeal, and remanded the case for further proceedings without addressing the merits of Patterson's contentions. View "PATTERSON v. THE STATE" on Justia Law

Jousha O’Shea Routh was convicted of felony murder and other crimes related to the shooting deaths of Saiful Bhuyia and Rizanul Islam. The incident occurred on September 10, 2017, when Bhuyia, Islam, and two other workers were closing a convenience store. Two men from a white car demanded money, chased Bhuyia and Islam, and shot them. Bhuyia died at the scene, and Islam died days later. Routh was identified through fingerprints on Bhuyia’s car and cell phone records. His girlfriend, Shea Paul, identified him as the shooter based on surveillance footage.A Fulton County grand jury indicted Routh on multiple counts, including malice murder and felony murder. The jury found him not guilty of malice murder of Islam, did not reach a verdict on the malice murder of Bhuyia, and found him guilty on other counts. The trial court sentenced Routh to two consecutive life sentences plus 35 years. Routh filed a motion for a new trial, which was denied by the trial court. He then filed a timely notice of appeal.The Supreme Court of Georgia reviewed the case. Routh argued that the trial court abused its discretion by limiting his cross-examination of the lead detective. The court found that the trial court had discretion to limit cross-examination to prevent unfair advantage and to conclude that questions about the age of fingerprints were outside the scope of the detective’s lay testimony. The court held that the trial court did not abuse its discretion in these rulings and affirmed Routh’s convictions. View "ROUTH v. THE STATE" on Justia Law

Deangelo Deshawn Morgan was convicted in 2023 for the fatal shooting of Sabron Mosby and the aggravated assault of Donoven King. The crimes occurred on October 15, 2018, and Morgan was indicted along with Cleavanta Jerrideau and Glenn Darius Smith. Morgan's trial was severed due to a conflict of interest with his counsel, and Jerrideau and Smith were acquitted in their joint trial. Morgan was later found guilty by a jury and sentenced to life in prison with the possibility of parole for malice murder and an additional twenty years for aggravated assault.Morgan's motion for a new trial was denied by the trial court after an evidentiary hearing. He appealed, arguing that the trial court abused its discretion by excluding evidence that the shooting was drug-related and implicating other potential suspects. He also claimed his trial counsel was ineffective for not properly arguing for the admission of this evidence and advising him not to testify.The Supreme Court of Georgia reviewed the case and found that the trial court did not abuse its discretion in excluding the evidence. The court held that the excluded evidence did not raise a reasonable inference of Morgan's innocence and was speculative. Additionally, the court found that Morgan's trial counsel's performance was not deficient, as the advice given was a strategic decision and not patently unreasonable.The Supreme Court of Georgia affirmed the trial court's decision, upholding Morgan's convictions and sentences. View "MORGAN v. THE STATE" on Justia Law

The appellant, Quillian Donta Nelson, was arrested on June 5, 2020, in connection with the shooting death of Darwin Davis. He filed a pre-indictment demand for a speedy trial on August 7, 2020. However, he was not indicted until August 23, 2021. His original defense attorney filed a motion for a continuance in March 2022, and later, a notice of leave for personal reasons. The defense counsel eventually withdrew, and substitute counsel appeared in February 2023. The new defense attorney also filed several notices of anticipated leaves of absence. Nelson filed a motion for an out-of-time statutory demand for a speedy trial in July 2023, which was denied. He then moved to dismiss his indictment on constitutional speedy-trial grounds in October 2023.The trial court denied Nelson's motion to dismiss the indictment, finding that the length of the delay was presumptively prejudicial but attributing the delay to the COVID-19 pandemic and defense counsel's requested continuances. The court weighed the assertion-of-the-right factor against Nelson, noting his late assertion of the right to a speedy trial, and found no evidence of prejudice to his defense.The Supreme Court of Georgia reviewed the case and found that the trial court made several errors. The trial court failed to properly consider the length-of-the-delay factor, made clearly erroneous findings regarding the reasons for the delay and the assertion of the right, and misapplied the law concerning the prejudice factor. The Supreme Court vacated the trial court's order and remanded the case for further consideration of Nelson's motion to dismiss the indictment on constitutional speedy-trial grounds. View "NELSON v. THE STATE" on Justia Law

Amanda Coleman was convicted of malice murder for the death of two-year-old Brooklyn Aldridge. Brooklyn died on March 6, 2018, and Coleman was indicted in August 2018. At trial in October 2019, Coleman was found guilty of both malice murder and felony murder, but the felony murder count was vacated by operation of law. Coleman was sentenced to life in prison without the possibility of parole. She filed a motion for a new trial, which was denied in July 2024. Coleman then appealed to the Supreme Court of Georgia.The trial court admitted evidence of Coleman’s methamphetamine use, which Coleman argued was inadmissible under OCGA § 24-4-403 and OCGA § 24-4-404 (b). The court ruled that the evidence was intrinsic and satisfied Rule 403’s balancing test. Coleman also challenged the reliability of the urine test showing methamphetamine use, but the court allowed it. Additionally, the court limited the testimony of Coleman’s expert witness regarding alternative causes of Brooklyn’s death, ruling that speculative opinions about pneumonia and DIC were inadmissible.The Supreme Court of Georgia reviewed the case and affirmed the trial court’s decisions. The court held that evidence of Coleman’s methamphetamine use was admissible as intrinsic evidence and that its probative value was not substantially outweighed by any unfair prejudice. The court also found that any error in admitting the urine test results was harmless because it was cumulative of Coleman’s own admissions of drug use. Regarding the expert testimony, the court concluded that excluding speculative opinions did not affect the trial’s outcome, as the jury had already rejected the theory of accidental injury.Finally, the court addressed Coleman’s claim of ineffective assistance of counsel, finding no prejudice from the failure to object to the prosecutor’s characterization of reasonable doubt during closing arguments. The court noted that the trial court properly instructed the jury on the correct standard for reasonable doubt. The Supreme Court of Georgia affirmed Coleman’s conviction and sentence. View "COLEMAN v. THE STATE" on Justia Law

Alfred Jermaine Arnold was convicted of malice murder and other crimes related to the death of Loretta Goolsby, who was beaten to death between April 5 and 6, 2019. Arnold was indicted on multiple counts, including malice murder, felony murder, aggravated assault, arson, and theft by taking. The jury found him guilty on all counts, and he was sentenced to life without parole for malice murder, plus additional concurrent sentences for arson and theft. Arnold's motion for a new trial was denied, leading to his appeal.Arnold argued that the evidence was insufficient to support the verdicts, his discovery rights were violated, his trial counsel was ineffective, and the trial court erred in admitting expert testimony. The Supreme Court of Georgia reviewed the case. The court found that the evidence, including cell phone location data, fingerprint evidence, and Arnold's inconsistent statements, was sufficient to support the convictions. The court also determined that there were no discovery violations, as Arnold had been provided with the expert's reports and was aware of the expert's conclusions.Regarding the ineffective assistance of counsel claim, the court concluded that Arnold's trial counsel's performance was not deficient, as they employed a reasonable strategy in handling the fingerprint evidence and cross-examining the expert. Additionally, Arnold failed to demonstrate that he was prejudiced by his counsel's performance, as he did not provide evidence that he would have accepted a plea offer or that an independent expert would have provided different testimony.The court also upheld the trial court's decision to admit the expert testimony under the Daubert standard and OCGA § 24-7-702 (b), finding that the expert was qualified and her methods were reliable. Consequently, the Supreme Court of Georgia affirmed Arnold's convictions. View "ARNOLD v. THE STATE" on Justia Law

Jose Carlos Carrillo was convicted in 2021 for felony murder and other crimes related to the shooting death of Shawn Rhinehart and the non-fatal shooting of Robert Reeves. The incident occurred on October 8, 2017, when Carrillo confronted Rhinehart and Reeves at a park. After a brief altercation, Carrillo followed them in an orange sports car and fired multiple shots, killing Rhinehart and injuring Reeves. Evidence included surveillance footage, witness testimonies, and ballistics linking a gun found in Carrillo's home to the crime scene.Carrillo was indicted by a Chatham County grand jury on multiple counts, including malice murder, felony murder, aggravated assault, and possession of a firearm by a First-Offender Probationer. He was tried separately and found guilty on all counts except malice murder. The trial court sentenced him to life in prison for felony murder and an additional 20 years for aggravated assault. Carrillo filed a motion for a new trial, which was denied by the trial court after an evidentiary hearing.The Supreme Court of Georgia reviewed Carrillo's appeal, where he claimed ineffective assistance of counsel. Carrillo argued that his counsel failed to object to the admission of certain text messages and did not renew an objection to the search warrant executed at his home. The court found that Carrillo did not demonstrate that any deficiency in failing to object to the text messages prejudiced him, nor did he show that his counsel acted deficiently regarding the search warrant. Consequently, the Supreme Court of Georgia affirmed the trial court's decision, upholding Carrillo's convictions and sentences. View "CARRILLO v. THE STATE" on Justia Law

Alex Lee Johnson was convicted of felony murder and other crimes related to the shooting death of Patricia Sabb. On the night of July 23, 2018, Sabb was shot twice while in her home in Savannah and later died from her wounds. The shots were fired from a car on the street. Johnson was involved in a dispute with Sabb's grandson, Rashamel Edwards, who was a member of the Crips gang. Johnson, also a gang member, had hijacked a car from Edwards, leading Edwards to threaten Johnson. The State argued that Johnson and others went to kill Edwards at Sabb's home, resulting in Sabb's death.A Chatham County grand jury indicted Johnson on multiple charges, including malice murder, felony murder, aggravated assault, and possession of a firearm. The jury found Johnson guilty of felony murder, hijacking a vehicle, armed robbery, and other charges but acquitted him of malice murder. The trial court sentenced Johnson to life in prison with the possibility of parole for felony murder, plus additional sentences for other counts. Johnson's motion for a new trial was granted in part regarding a merger issue, leading to an amended sentencing order. The trial court denied the motion on other grounds, and Johnson appealed.The Supreme Court of Georgia reviewed the case and affirmed Johnson's convictions. The court held that the trial court did not abuse its discretion in admitting evidence of Johnson's gang membership, as it was relevant to his motive and the probative value outweighed any potential prejudice. The court also found that any error in failing to instruct the jury on lesser-included offenses was harmless, as the jury would likely have convicted Johnson of the greater offenses regardless. View "JOHNSON v. THE STATE" on Justia Law