Justia Criminal Law Opinion Summaries

Undrea Burley was convicted by jury of felony murder in connection with the beating death of Joshua Brooks. Burley contended the trial court plainly erred by failing to instruct the jury sua sponte on the elements of malice murder because the indictment charged Burley and his co-defendants, Wesley Adams and Demetrious Smith, with felony murder predicated on “aggravated assault with intent to murder.” The Georgia Supreme Court found the trial court’s instructions concerning the offenses of felony murder and aggravated assault with intent to murder, though erroneous, did not constitute plain error requiring reversal. Therefore, the Court affirmed the judgment of conviction. View "Burley v. Georgia" on Justia Law

Geovanni Perez was convicted of felony murder and a firearm offense in connection with the 2018 shooting death of Rahmier Gardner. Perez contended on appeal: (1) that the evidence was constitutionally insufficient to support his conviction for felony murder based on armed robbery; (2) the trial court erred by denying his motions to suppress certain evidence; and that he was improperly sentenced. Seeing no error, the Georgia Supreme Court affirmed. View "Perez v. Georgia" on Justia Law

Appellant Dennaryl Head was convicted of felony murder and other crimes in connection with the 2006 shooting death of Dwight Smith. On appeal, Head contended that: (1) the evidence presented at trial was legally insufficient to sustain the verdict against him under former OCGA § 24-4-8; and (2) the trial court abused its discretion under former OCGA § 24-3-1 by admitting hearsay testimony from a police detective. The Georgia Supreme Court concluded that the evidence was sufficient under former OCGA § 24-4-8 because the testimony of Head’s accomplice was sufficiently corroborated. "And, pretermitting whether the trial court erred in admitting the challenged testimony," the Court concluded any error was harmless. View "Head v. Georgia" on Justia Law

Appellant Garrett Davis was convicted of felony murder in connection with the 2012 shooting death of Eugene Stinchcomb. On appeal, Davis contended: (1) the evidence was legally insufficient to support his convictions; (2) his trial counsel provided constitutionally ineffective assistance; (3) the trial court erred by failing to instruct the jury on confession corroboration; and (4) the trial court erred by failing to grant a new trial based on prosecutorial misconduct. Finding no reversible error in the trial court's judgment, the Georgia Supreme Court affirmed. View "Davis v. Georgia" on Justia Law

Appellant Trevis Price was convicted by jury of malice murder and other offenses in connection with the deaths of L. C. Tumblin Jr. and Dexter Covin. On appeal, Price challenged the sufficiency of the evidence supporting his convictions for malice murder and the trial court’s denial of his motion to sever the charge for possession of cocaine with intent to distribute. Finding no reversible error in the trial court's judgment, the Georgia Supreme Court affirmed. View "Price v. Georgia" on Justia Law

In 2007, Jeremy Moody was charged with the rape and murder of 13-year-old Chrisondra Kimble and the murder of Kimble’s 15-year-old cousin, Delarlonva Mattox, Jr., and other related offenses. Shortly after Moody’s jury trial began in April 2013, Moody pleaded guilty to two counts each of malice murder, felony murder predicated on aggravated assault, aggravated assault, aggravated assault with intent to rob, and kidnapping with bodily injury, as well as to one count of rape. At the conclusion of the sentencing phase, a jury found the existence of multiple statutory aggravating circumstances as to each murder and recommended a sentence of death for each murder, and the trial court sentenced Moody accordingly. On appeal, Moody raised thirteen claims of error, each of which the Georgia Supreme Court rejected, affirming the convictions and sentence. View "Moody v. Georgia" on Justia Law

Appellant Dwight Blalock, Jr., was convicted of malice murder and other crimes in connection with the 2014 fatal shooting of Carlos Wright and the aggravated assault of Bryan Morrow. On appeal, Blalock contended: (1) the trial court abused its discretion and denied Blalock due process by refusing to grant his motion for continuance; (2) Blalock’s trial counsel rendered ineffective assistance by failing to argue that the discovery statute, OCGA § 17-16-4, was unconstitutional as applied in this case; and (3) the trial court erred in permitting a State’s witness to comment on Blalock’s silence. Finding no reversible error, the Georgia Supreme Court affirmed Blalock’s convictions. View "Blalock v. Georgia" on Justia Law

A habeas court granted relief to Jonathon Medina on the grounds that his guilty plea was involuntary and trial counsel was ineffective. Timothy Ward, the Commissioner of the Georgia Department of Corrections, appealed the habeas court’s order, challenging each of those grounds. Because the Georgia Supreme Court concluded the habeas court did not err in granting relief to Medina on his involuntary-plea claim, and affirmed the habeas court’s decision on that ground without addressing that court’s rulings on Medina’s ineffective assistance claims. View "Ward v. Medina" on Justia Law

In 2017, Erasmus Chandler was found guilty by jury of aggravated child molestation and two counts of child molestation. In 2019, the Court of Appeals affirmed his convictions in an unpublished opinion. Chandler later filed a pro se petition for habeas corpus, which the habeas court granted in 2022 on the ground that Chandler’s appellate counsel provided ineffective assistance at the motion for new trial stage and on appeal, including by failing to raise and prove claims of ineffective assistance of trial counsel. Warden Aimee Smith appealed, arguing that the habeas court erred in admitting an exhibit at the habeas hearing and in determining that Chandler’s appellate counsel provided ineffective assistance. The Georgia Supreme Court found the the warden did not object to the admission of the challenged exhibit for the limited purpose for which it was admitted, and on appeal the warden has not shown plain error in its admission. Moreover, the habeas court properly determined that Chandler’s appellate counsel provided ineffective assistance at the motion for new trial stage and on appeal by failing to raise and prove a claim of ineffective assistance of trial counsel for failing to impeach the alleged victim’s testimony at trial with evidence that she had made prior inconsistent statements about the alleged abuse. Accordingly, the Supreme Court affirmed the habeas court’s grant of relief on this basis. View "Smith v. Chandler" on Justia Law

Brandon Williams appealed his convictions for malice murder and possession of a firearm during the commission of a felony in connection with the shooting death of Corey Coleman. Williams contended the trial court erred: (1) when it did not allow him to show his left arm during the cross-examination of a detective; (2) when it allowed testimony about a deceased person’s out-of-court identification of Williams; (3) when it failed to charge the jury on self-defense; and (4) when it allowed introduction of Coleman’s statements to his mother. Williams also contended he received ineffective assistance of trial counsel. Finally, Williams argued the cumulative errors created sufficient prejudice that he must receive a new trial. Because Williams failed to show reversible error, the Georgia Supreme Court affirmed. View "Williams v. Georgia" on Justia Law