Justia Criminal Law Opinion Summaries

On August 6, 2017, the appellant was involved in a fatal shooting after arranging to meet the victim, with whom he had a history of marijuana transactions. The meeting took place at an apartment complex where the appellant was staying. Witnesses observed the appellant acting nervously and possibly carrying a handgun. After the victim arrived, gunshots were heard, and the appellant was seen fleeing with what appeared to be a gun. He returned to the apartment, admitted to shooting someone, and then left the scene without contacting authorities. The victim was found dead with two gunshot wounds, and ballistic evidence linked the shots to a .45-caliber handgun. The appellant, a convicted felon, later testified that he shot the victim in self-defense during an attempted robbery.A Clayton County grand jury indicted the appellant for malice murder, felony murder, aggravated assault, and possession of a firearm by a convicted felon. At trial, the jury found him guilty on all counts. The trial court sentenced him to life without parole for malice murder, with additional consecutive sentences for aggravated assault and firearm possession. The felony murder counts were vacated by operation of law, and one aggravated assault count merged with the malice murder conviction. The appellant filed a motion for a new trial, which was initially granted but then vacated; the motion was ultimately denied. The case was transferred from the Court of Appeals to the Supreme Court of Georgia.The Supreme Court of Georgia held that the appellant’s trial counsel did not render ineffective assistance by failing to stipulate to his felon status or by eliciting testimony about his juvenile history, as these were either not deficient or were reasonable strategic decisions. However, the Court found a merger error regarding the aggravated assault conviction for the non-fatal shot and vacated that conviction and sentence. The remainder of the judgment was affirmed. View "FRASER v. THE STATE" on Justia Law

On August 29, 2019, the appellant was involved in a fatal shooting at a hotel in Gwinnett County, Georgia. The incident arose from a planned drug transaction involving methamphetamine, in which the appellant, along with two co-defendants, participated. The victim, who was a friend of one co-defendant, was shot and killed during the attempted drug deal. The appellant was later arrested, and his statements to police, as well as his trial testimony, indicated his involvement in the conspiracy to possess methamphetamine with intent to distribute. Surveillance footage, witness testimony, and physical evidence corroborated the sequence of events leading to the shooting.A Gwinnett County grand jury indicted the appellant and others on multiple charges, including felony murder predicated on conspiracy to possess methamphetamine with intent to distribute. At trial in the Superior Court of Gwinnett County, the jury found the appellant guilty of felony murder based on the drug conspiracy, conspiracy to violate the Georgia Controlled Substances Act, and possession of a firearm during the commission of a crime. He was acquitted of other charges. The trial court sentenced him to life without parole plus a consecutive five-year term. After his motion for a new trial was denied, the appellant appealed.The Supreme Court of Georgia reviewed the case, focusing on whether the evidence was constitutionally sufficient to support the felony murder conviction predicated on the drug conspiracy. The Court held that the evidence, viewed in the light most favorable to the verdict, was sufficient for a rational jury to find the appellant guilty beyond a reasonable doubt. The Court concluded that a conspiracy to possess methamphetamine with intent to distribute is inherently dangerous and that the victim’s death was a reasonably foreseeable consequence of the conspiracy. The judgment was affirmed. View "PINION-LOPEZ v. THE STATE" on Justia Law

Two individuals, India Royal and Cameron Woods, were found shot to death in their car in a Walmart parking lot in Riverdale, Georgia, on January 13, 2017. The investigation revealed that both victims were killed by 9mm bullets while seated in their vehicle, which contained evidence of drug distribution. Surveillance footage showed a distinctive white Mercury Mountaineer circling the parking lot before the shooting, and a tall man was seen exiting the Mountaineer, entering the victims’ car, and then leaving shortly before the Mountaineer drove away. The vehicle was registered to the appellant’s mother, who confirmed that her son, Deanthony Ealey, had possession of it that day. Cell phone records linked communications between Woods and a number associated with Ealey around the time of the murders. Ealey was later identified as the person driving the Mountaineer at a nearby ATM after the murders.The Superior Court of Clayton County tried Ealey on two counts of malice murder, two counts of felony murder, and two counts of aggravated assault. The jury found him guilty on all counts, and he was sentenced to consecutive life terms without parole. Ealey filed a motion for a new trial, which was denied after evidentiary hearings.The Supreme Court of Georgia reviewed Ealey’s appeal, in which he argued that the evidence was insufficient, that the trial court erred in admitting other-acts and hearsay evidence, that his counsel was ineffective, and that cumulative errors warranted reversal. The court held that the evidence was sufficient to support the convictions under both constitutional and Georgia statutory standards, that any errors in admitting other-acts or hearsay evidence were harmless, and that Ealey failed to show ineffective assistance or cumulative error. The Supreme Court of Georgia affirmed Ealey’s convictions and sentences. View "EALEY v. THE STATE" on Justia Law

The case concerns an incident in which Roy Blane Dees attacked Jimmy Vance with a hammer in Vance’s front yard, resulting in Vance’s death a few days later. Several neighbors either witnessed or heard the attack and later identified Dees as the assailant. After the assault, Dees left the scene and was eventually apprehended at a nearby gas station. The evidence at trial included eyewitness testimony, a 9-1-1 call, and police body camera footage capturing witness statements at the scene.A Rockdale County grand jury indicted Dees on multiple charges, including malice murder, felony murder, aggravated assault, and aggravated battery. At trial in the Superior Court of Rockdale County, the jury found Dees guilty of felony murder predicated on aggravated assault and aggravated assault, but acquitted him of the other charges. The court sentenced Dees to life in prison without parole. Dees filed a motion for a new trial, which was denied, and then appealed his convictions.The Supreme Court of Georgia reviewed Dees’s claim that the trial court erred by admitting police officers’ testimony recounting what witnesses told them at the scene, arguing this was inadmissible hearsay. Because Dees did not object at trial, the Court applied the plain error standard. The Court held that, under Georgia law, hearsay evidence is admissible if not properly objected to, and no controlling authority required the trial court to exclude such evidence sua sponte. Therefore, the trial court did not commit plain error, and the Supreme Court of Georgia affirmed Dees’s convictions. View "DEES v. THE STATE" on Justia Law

Edward Morris was convicted by a jury of murder, aggravated assault, criminal street gang activity, and related offenses stemming from two incidents involving victims Randy Griffin and Lacey Magee. Morris was a member of a group known as the International Robbing Club (IRC), which planned and executed robberies. In May 2007, IRC members attempted to rob Griffin, resulting in Magee being shot and Griffin returning fire. Later, in June 2007, Griffin was shot and killed outside a nightclub, with evidence including accomplice testimony, cell tower records, and statements from Morris’s former girlfriend placing Morris at the scene and implicating him in the planning and execution of the crime.After his conviction, Morris’s trial counsel withdrew a motion for new trial and filed an appeal. The Supreme Court of Georgia affirmed Morris’s convictions, finding the evidence sufficient. Morris later filed a habeas corpus petition, alleging ineffective assistance of both trial and appellate counsel on several grounds, including failure to ensure his presence at bench conferences, failure to consult or call a cell tower expert, failure to interview or call a co-indictee as a witness, and withdrawal of the motion for new trial without his consent. The habeas court granted relief on all but one claim.The Supreme Court of Georgia reviewed the habeas court’s decision and reversed the grant of relief on all grounds except one, which was remanded for further consideration. The Court held that Morris’s claims of ineffective assistance of trial counsel were procedurally defaulted and that he failed to show appellate counsel was ineffective for not raising those claims. The Court also found that appellate counsel was not ineffective for failing to raise other direct claims. The disposition was reversed in part and remanded in part. View "SPRAYBERRY v. MORRIS" on Justia Law

The case concerns a man who was convicted of malice murder and related offenses following the death of his girlfriend. The two had a tumultuous relationship, and on the day in question, the victim was last heard from after telling her cousin she planned to leave the defendant. The next day, the defendant’s brother discovered the couple’s home on fire, and the victim was found dead inside. Investigators determined the fire was intentionally set and that the victim had died from neck compression before the fire started. The defendant gave conflicting accounts to law enforcement, ultimately admitting to setting the fire to cover up the death and to strangling the victim, though he claimed it was not intentional and that she had pointed a gun at him.A Warren County jury found the defendant guilty on all counts, including malice murder, arson, and concealing a death. The trial court sentenced him to life without parole for malice murder, with additional terms for arson and concealing a death. The felony murder conviction was vacated by operation of law, and the aggravated assault count was merged with the vacated felony murder count. The defendant’s motion for a new trial was denied by the Superior Court of Warren County.On appeal, the Supreme Court of Georgia reviewed the sufficiency of the evidence and the trial court’s handling of the motion for new trial. The Court held that the evidence included direct admissions by the defendant and was not solely circumstantial, so the statutory standard for circumstantial evidence did not apply. The Court also found that the trial court properly exercised its discretion as the “thirteenth juror” in denying a new trial. The Supreme Court of Georgia affirmed the convictions. View "TUCKER v. THE STATE" on Justia Law

Antonio Payne was indicted for the murder of Warren Sills and the aggravated assault of Dondrey Moore after a shooting in a DeKalb County apartment complex parking lot in April 2019. The evidence at trial included eyewitness testimony from Rozier (Payne’s brother), Moore (the surviving victim), and Kristie Barlow (Payne’s cousin), all of whom implicated Payne as the shooter. Moore identified Payne both in a photo lineup two months after the shooting and in court, stating he was “100% accurate” in his identification. Physical evidence, such as the type of bullet recovered and the absence of shell casings, supported the eyewitness accounts that Payne used a revolver.Following a jury trial in the Superior Court of DeKalb County, Payne was convicted of malice murder, felony murder predicated on aggravated assault, and aggravated assault of Moore. The aggravated assault count involving Sills merged, and the felony murder count was vacated by operation of law. Payne was sentenced to life without parole for murder and 20 years concurrent for aggravated assault. He filed a motion for new trial, which was denied, and then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Payne’s claims that the trial court erred in admitting Moore’s out-of-court identification and that his counsel was ineffective for failing to object to the prosecutor’s explanation of reasonable doubt. The Court held that the identification procedure was not impermissibly suggestive and that Payne failed to show prejudice from counsel’s deficient performance regarding the closing argument. The judgment of the trial court was affirmed. View "PAYNE v. THE STATE" on Justia Law

A three-year-old child, Elisha, died after sustaining numerous injuries while in the care of his mother’s boyfriend, the defendant. On the day of the incident, Elisha was left alone with the defendant while his mother worked. The child was healthy earlier that day, but later that evening, the defendant reported to the mother that Elisha’s breathing was abnormal. When the mother returned home, Elisha was unresponsive and was taken to the hospital, where he was found to have extensive bruising and head trauma. The defendant initially claimed Elisha was injured by falling while playing with a dog, but later admitted to striking the child with a belt, though he maintained the fatal injuries were accidental.A Wayne County grand jury indicted the defendant for felony murder and cruelty to children in the first degree. After a jury trial in the Superior Court of Wayne County, the defendant was found guilty on both counts. He was sentenced to life imprisonment without parole. The defendant filed several motions for a new trial, represented by different counsel at various times, but the trial court ultimately denied these motions.On appeal to the Supreme Court of Georgia, the defendant argued that the evidence was insufficient to support his convictions and that the trial court erred in denying his request for a continuance to obtain new counsel. The Supreme Court of Georgia held that the evidence was sufficient for a rational jury to find the defendant guilty beyond a reasonable doubt, and that the trial court did not abuse its discretion in denying the continuance, as there was no showing that counsel was unprepared or that a different attorney was warranted. The court affirmed the convictions. View "FOSTER v. THE STATE" on Justia Law

In this case, the defendant was charged with multiple crimes, including malice murder, in connection with the shooting death of a taxi driver. The incident occurred in the early morning hours when the defendant, after an altercation with the victim, struck him multiple times with a tire iron and then shot him in the head. Eyewitnesses described seeing the defendant repeatedly beat the victim and then shoot him before taking the victim’s taxi and fleeing the scene. The defendant later sold the victim’s cell phone and was linked to the crime through physical evidence, including DNA and surveillance footage. The medical examiner determined that the victim died from a gunshot wound to the head, with blunt-force injuries as contributing factors.A Fulton County grand jury indicted the defendant on charges including malice murder, felony murder, armed robbery, aggravated assault, hijacking a motor vehicle, and weapons offenses. At trial in the Superior Court of Fulton County, the jury found the defendant guilty on all counts. The court sentenced him to life without parole for malice murder and imposed additional consecutive and concurrent sentences for other offenses. The defendant filed a motion for a new trial, which was denied.On appeal, the Supreme Court of Georgia reviewed the sufficiency of the evidence regarding the defendant’s affirmative defenses of self-defense and justification, as well as the trial court’s decision not to merge the aggravated assault count into the malice murder conviction. The court held that the evidence was sufficient for the jury to reject the defendant’s self-defense claim and that there was a deliberate interval between the beating and the shooting, supporting separate convictions. The Supreme Court of Georgia affirmed the convictions and sentences. View "ALLEN v. THE STATE" on Justia Law

The case concerns the shooting death of Brian Christopher Johnson, who was last seen on October 19, 2016, with Richard Walton and Clifford Duckworth, III. Johnson was found dead the next day on a dirt road, having suffered a gunshot wound to the face, with his pockets turned out and his wallet, phone, and cash missing. Evidence linked Walton to the crime, including Johnson’s blood on Walton’s shoes and testimony from witnesses and Walton’s cellmate, who recounted Walton’s admission to the shooting and subsequent disposal of Johnson’s belongings. The investigation also uncovered gang-related materials and testimony about Walton’s affiliation with the Gangster Disciples.A Washington County grand jury indicted Walton and Duckworth on multiple charges, but charges against Duckworth were dismissed. Walton was tried and acquitted of malice murder and one firearm count but convicted of felony murder, armed robbery, aggravated assault, and related firearm offenses. The Superior Court of Washington County sentenced him to life without parole plus additional years for the firearm offenses. Walton’s motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed several claims, including alleged errors in denying a directed verdict, admitting gang-related evidence, use of a transcript during trial, and the admission of certain out-of-court statements. The court held that Walton failed to preserve some claims for review, did not show plain error in the admission of contested evidence, and failed to demonstrate ineffective assistance of counsel, with several claims deemed abandoned. The court affirmed Walton’s convictions, finding no reversible error or cumulative prejudice warranting a new trial. View "WALTON v. THE STATE" on Justia Law