Justia Criminal Law Opinion Summaries

Torres Boles appealed his convictions for felony murder and other charges in connection with the death of his three-year-old daughter, Andraia Boles. He argued on appeal that the evidence was insufficient to support his convictions and that the trial court erred in admitting into evidence statements he made to “Ms. Middleton,” a protective services investigator and case manager with the Georgia Department of Family and Children Services (“DFCS”) and to Renee Sylvester, a private-sector counselor hired by DFCS in connection with the agency’s investigation into placing Boles’s other daughter into foster care. Boles argued that the two DFCS investigators were acting as agents of law enforcement when they interviewed him and their failure to give him warnings under Miranda v. Arizona, 384 U.S. 436 (1966), rendered his statements inadmissible. After review, the Georgia Supreme Court concluded the evidence was sufficient to support Boles’s convictions, there was no error in the admission of Boles’s statement to Middleton, and any error in the admission of his statement to Sylvester was harmless, as such evidence was cumulative of other, properly admitted evidence. Accordingly, the convictions were affirmed. View "Boles v. Georgia" on Justia Law

Appellant Tyree Ingram was convicted of felony murder and other crimes in connection with the fatal shooting of LaMarcus Brown during the early morning hours of September 13, 2019. On appeal, Ingram contended his trial counsel rendered ineffective assistance by: (1) failing to object to good character evidence of the victim; (2) failing to object to and redact the portion of Ingram’s recorded statement to law enforcement officers where he mentioned his juvenile criminal history; and (3) failing to object to the classification of Ingram’s first offender sentence as a “conviction” when it was tendered into evidence by the State. Ingram also contended that the cumulative effect of trial counsel’s ineffectiveness entitled him to a new trial. Finding no ineffective assistance of counsel, the Georgia Supreme Court affirmed. View "Ingram v. Georgia" on Justia Law

Derrick Session challenged his convictions for failing to register as a sex offender in Georgia based on a conviction he received in Louisiana. He argued: (1) the evidence was insufficient to support his Georgia convictions; (2) the Georgia registration statute as applied to him violated his federal rights to travel and equal protection; and (3) he raised a facial challenge to the registration statute under the Georgia constitutional prohibition against legislation regarding the social status of citizens. After thorough consideration, the Georgia Supreme Court rejected those arguments and affirmed. View "Session v. Georgia" on Justia Law

Appellant Anthony Martin challenged his 2015 convictions for felony murder and a firearm offense in connection with the shooting death of Marlon Underwood. Appellant’s only enumeration of error was that the evidence presented at trial was legally insufficient to support his convictions as a matter of constitutional due process and Georgia statutory law. When properly viewed in the light most favorable to the jury’s verdicts, the Georgia Supreme Court found the evidence was sufficient to support Appellant’s convictions. Accordingly, the convictions were affirmed. View "Martin v. Georgia" on Justia Law

Evins Vontravis Harris was convicted by jury of felony murder and other crimes in connection with the 2018 shooting death of Darius Roberts. On appeal, Harris argued the trial court erred in denying him immunity from prosecution and abused its discretion by admitting an in-life photograph of Darius at trial. Finding no reversible error, the Georgia Supreme Court affirmed Harris' convictions. View "Harris v. Georgia" on Justia Law

Appellant Brandon Williams was convicted of malice murder in connection with the February 2016 shooting death of Kavozia Walker. On appeal, Appellant contended: (1) insufficient evidence supported his conviction; (2) the trial court erred in imposing a recidivist sentence of life imprisonment without the possibility of parole, rather than exercising its discretion to consider a life-with-parole sentence for murder; and (3) the trial court erred in merging the felony-murder count into the malice-murder count for sentencing purposes, rather than vacating the felony-murder count by operation of law. Finding no reversible error, the Georgia Supreme Court affirmed. View "Williams v. Georgia" on Justia Law

Appellant Bernard Brock challenged his convictions for malice murder and other crimes arising out of the 2015 beating death of Marlene Murray. On appeal, Appellant argued the trial court abused its discretion in admitting, pursuant to OCGA § 24-4-404 (b) (“Rule 404 (b)”), evidence that in June 2014 he had beaten Ansley Minkema, his girlfriend and co-defendant. Appellant also claimed that when Minkema’s testimony did not match the State’s pretrial proffer, the trial court erred in not reversing its earlier ruling and striking her testimony and, relatedly, that his trial counsel performed deficiently in failing to move to strike her testimony. The Georgia Supreme Court concluded that even if the trial court erred in admitting or failing to strike Minkema's testimony, the error was harmless. Appellant’s claim that trial counsel provided ineffective assistance in failing to move to strike Minkema’s testimony about the assault was waived. Accordingly, the Court affirmed Appellant’s convictions. View "Brock v. Georgia" on Justia Law

Appellant Joseph Priester was convicted of malice murder and related offenses in connection with the May 2017 shooting death of Genaro Rojas-Martinez. On appeal, Appellant contended: (1) the trial court erred in admitting evidence of an armed robbery and shooting Appellant allegedly committed the day before the murder, pursuant to OCGA § 24-4-404 (b) (“Rule 404 (b)”); and (2) the trial court erred in instructing the jury that it could consider the prior armed-robbery and shooting evidence for the purposes of opportunity, intent, knowledge, and lack of mistake or accident. Finding no reversible error, the Georgia Supreme Court affirmed. View "Priester v. Georgia" on Justia Law

Brandon Fuller was convicted by jury of malice murder and possession of a firearm during the commission of a felony in connection with the shooting death of Daniel Landy. On appeal, Fuller contended he was denied constitutionally effective assistance of counsel and that the cumulative effect of trial counsel’s errors prejudiced him. Finding no such errors, the Georgia Supreme Court affirmed Fuller's conviction. View "Fuller v. Georgia" on Justia Law

Roden Meadows appealed his convictions for murder, aggravated assault, and possession of a firearm during the commission of a felony arising from the 2018 fatal shooting of Jason Williams. On appeal, Meadows contended the evidence constitutionally insufficient and that the Georgia Supreme Court should exercise its authority under OCGA §§ 5-5-20 and 5-5-21 as the “thirteenth juror” and grant him a new trial. He also argued the trial court erred in three instances by failing to rebuke the prosecutor for making improper and prejudicial statements during closing arguments. The Supreme Court concluded the evidence was sufficient to sustain Meadows’s convictions, and that it did not have authority under the cited statutory law to sit as the “thirteenth juror.” The Court also concluded Meadows failed to preserve his challenges to two of the prosecutor’s statements during closing arguments, and with respect to the third instance, even if the trial court erred by failing to rebuke the prosecutor, any error was harmless. Although not raised by Meadows on appeal, the Court identified in the record a merger error related to the sentence the trial court entered on Count 3 of the indictment. Because the Supreme Court could not resolve this sentencing issue based on the record, it vacated the merger of and sentence on Count 3 and remanded to the trial court for further proceedings. View "Meadows v. Georgia" on Justia Law