Justia Criminal Law Opinion Summaries

Brandon Williams was charged with multiple crimes, including two counts of malice murder, following the deaths of Natalie Nation and her son, Cole Nation. Williams lived with his father and Natalie, while Cole sometimes stayed with them. On the night of the incident, witnesses heard Williams yelling threats at Natalie, including statements like “I’m going to kill all of you.” Later, Williams’s father found Natalie and Cole unconscious in Natalie’s room, with a towel tied around Natalie’s neck. Both victims died from asphyxia, and Cole also suffered blunt-force trauma. Williams was arrested at a nearby gas station, and his DNA was found on the towel used in the crime.After a jury trial in the Superior Court of Gwinnett County, Williams was found guilty on all counts. He was sentenced to consecutive life sentences without parole for the malice murder convictions. The trial court merged the remaining counts with the malice murder counts, though the felony murder counts were vacated by law and the cruelty to children count should not have merged. Williams’s motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Williams’s claim that the trial court erred by admitting a hearsay statement under the residual hearsay exception. The statement, made by Natalie to a friend, described a prior incident in which Williams had choked her. The Supreme Court held that the trial court did not abuse its discretion in admitting the statement, finding it met the requirements of trustworthiness, materiality, and probative value under OCGA § 24-8-807. The Supreme Court of Georgia affirmed Williams’s convictions. View "Williams v. State" on Justia Law

Two defendants were convicted by a jury of felony murder and related offenses after a fatal shooting outside a game room. The incident involved a physical altercation between the victim and the defendants, during which the victim was shot multiple times and his cell phone was taken. Eyewitnesses placed the defendants at the scene, described a fight immediately preceding the shooting, and identified one defendant as the shooter. DNA evidence linked one defendant to the victim, and both defendants gave inconsistent statements to investigators. The prosecution also introduced evidence of gang affiliation and suggested a motive related to the victim’s cooperation with law enforcement.The case was tried in the Superior Court of Emanuel County, where the jury found both defendants guilty on most counts. The trial court sentenced them to life imprisonment and denied their motions for new trial, except as to the gang-related charge, which the court found was not supported by sufficient evidence. The court’s rationale for reversing the gang conviction barred retrial on that count, and the State entered a nolle prosequi for it. The defendants appealed, challenging the sufficiency of the evidence, the admission of certain testimony, and the denial of their motions for directed verdict and new trial.The Supreme Court of Georgia reviewed the appeals. It held that the evidence, viewed in the light most favorable to the verdicts, was sufficient for a rational jury to find both defendants guilty beyond a reasonable doubt, including as parties to the crimes. The Court found no error in the admission of prior inconsistent statements or in the trial court’s handling of the gang evidence. The Court also determined that the trial court properly exercised its discretion in denying the motions for new trial on the general grounds. The convictions were affirmed, except for the gang-related count, which was not at issue on appeal. View "Bostic v. State" on Justia Law

A group of teenagers and young adults devised a plan to rob and murder a man, Justin McKinney, and his girlfriend, Anna Franklin, as revenge for a drug-related incident involving one of the conspirators’ brothers. On the night of the crime, several of the group entered the victims’ home, where one participant shot and killed McKinney, and another shot and wounded Franklin. The group then fled, disposed of weapons, and made incriminating statements. Franklin survived and identified some of the assailants. Physical evidence, including firearms and shell casings, corroborated the events described by witnesses and participants.After the incident, several co-defendants pleaded guilty, while one was tried separately. The appellant, who was a juvenile at the time, was tried by a jury in the Superior Court of Fannin County and found guilty on all counts, including malice murder, attempted murder, and related offenses. He was sentenced to life in prison plus additional consecutive and concurrent terms. The trial court denied his motion for a new trial.The Supreme Court of Georgia reviewed the case. The appellant argued that his custodial statements should have been suppressed due to his age, learning disability, and other factors; that the trial court erred by modifying a pattern jury instruction to include “age” as a factor not to influence the jury; and that a post-incision autopsy photograph was improperly admitted. The Supreme Court of Georgia held that the trial court did not err in admitting the custodial statements, as the totality of the circumstances showed a knowing and voluntary waiver of rights. The Court also found no plain error in the jury instruction and no abuse of discretion in admitting the autopsy photograph. The convictions and sentences were affirmed. View "Hill v. State" on Justia Law

A group of teenagers, including the appellants, committed a series of armed robberies and a murder over a three-day period in October 2018 in Suwanee, Georgia. The crimes included the shooting death of Willian Tunchez and the robberies of four other individuals. The group, associated with the Gangster Disciples street gang, planned and executed these crimes, often using firearms and dividing the stolen proceeds. Evidence included testimony from accomplices, physical evidence recovered from the defendants’ residences, and digital evidence from cell phones and social media.Following these events, a Gwinnett County grand jury indicted several individuals on multiple counts, including malice murder, armed robbery, aggravated assault, and violations of the Street Gang Terrorism and Prevention Act. Some co-defendants agreed to testify for the State. After a joint jury trial in the Superior Court of Gwinnett County, the jury found the appellants guilty on most counts. The trial court sentenced both to life imprisonment without parole for malice murder, with additional concurrent and consecutive sentences for other offenses. The court merged certain counts for sentencing and vacated others by operation of law. Both appellants filed timely motions for new trial, which were denied, and then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the sufficiency of the evidence, claims of ineffective assistance of counsel, and alleged sentencing errors. The Court held that there was sufficient direct evidence to support the convictions, that trial counsel was not constitutionally ineffective, and that most sentencing decisions were correct. However, the Court found that the trial court erred by failing to merge one aggravated assault count with an armed robbery count for one appellant, vacating that sentence but otherwise affirming the convictions and sentences. View "Evans v. State" on Justia Law

The case concerns a shooting that occurred in the early morning hours of February 2, 2017, following a series of arguments between Dwight Lewis and his former girlfriend, Dyreaka Tucker, regarding childcare. Witnesses, including a security guard familiar with both parties, observed heated exchanges between Lewis and Tucker, culminating in Lewis making a threatening remark. Shortly thereafter, as Tucker entered a car with friends, Lewis approached and fired into the vehicle, fatally striking Keosha Tinch. Tucker initially identified Lewis as the shooter to police and in her trial testimony, though she later recanted and gave inconsistent statements. Lewis fled the state and was apprehended in Detroit, where he provided false identification before admitting his identity.A Fulton County grand jury indicted Lewis on multiple charges, including malice murder, felony murder, aggravated assault, and weapons offenses. At trial in the Superior Court of Fulton County, a jury found Lewis guilty on all counts. The court sentenced him to life imprisonment with the possibility of parole, plus additional consecutive and concurrent terms for related offenses. Lewis’s motion for a new trial was denied after an evidentiary hearing.On appeal, the Supreme Court of Georgia reviewed Lewis’s claims that the evidence was insufficient to support his convictions and that the trial court erred by not instructing the jury on voluntary manslaughter. The court held that the evidence, viewed in the light most favorable to the verdict, was sufficient for a rational jury to find Lewis guilty beyond a reasonable doubt. The court also held that, absent a written request, the trial court’s failure to instruct on a lesser offense was not plain error. The Supreme Court of Georgia affirmed the convictions and sentences. View "Lewis v. State" on Justia Law

The case concerns a shooting death that occurred on November 24, 2015. The victim, Jeffery Anderson, was found shot twice in the head at his residence. Investigators determined that Anderson was a member of the Nine Trey gang and owed money to Gordon Evans, who held a leadership position in the gang. Evidence showed that Evans ordered two fellow gang members, Dossie Mann and Durell Lewis, to kill Anderson after Anderson failed to repay the debt. Mann and Lewis carried out the murder, and Evans later attempted to prevent Mann from testifying by ordering another gang member to kill Mann and his family. Evans was indicted on multiple charges, including malice murder, felony murder, aggravated assault, aggravated battery, false imprisonment, and criminal gang activity.The Superior Court of Gwinnett County held a jury trial in August 2018, where Evans was found guilty on all charges. He was sentenced to life in prison without parole for malice murder, with additional consecutive and concurrent sentences for other offenses. Evans filed a motion for a new trial, which was denied after a hearing in October 2024. He then appealed, challenging the admission of certain evidence and alleging ineffective assistance of counsel.The Supreme Court of Georgia reviewed the case. The court held that the admission of a letter found in Evans’s prison locker did not violate the Confrontation Clause because the author testified and was cross-examined. Any hearsay error was deemed harmless, as the evidence was cumulative. The court also found no abuse of discretion in admitting a handwriting expert’s testimony and upheld the admission of Mann’s videotaped interview under the forfeiture by wrongdoing doctrine. Evans’s claims of ineffective assistance of counsel were rejected. However, the court vacated the sentences for aggravated assault and aggravated battery, finding they should have merged with the murder conviction. The judgment was affirmed in part and vacated in part. View "Evans v. State" on Justia Law

On November 18, 2020, Juanita McFadden was shot and killed in the entrance hall of an apartment shared by Carl Crawford and his roommate, Jarvon Whitehead, in Cobb County, Georgia. The evidence at trial showed that McFadden and Crawford had a tumultuous relationship, with frequent arguments and occasional physical altercations. On the night of the incident, McFadden came to the apartment to collect her belongings, and after a heated exchange, Crawford shot her multiple times. Crawford claimed self-defense, asserting that he suffered from battered person syndrome due to his relationship with McFadden. The investigation revealed that McFadden was unarmed at the time of the shooting, and Crawford admitted to shooting her after she allegedly struck him.A Cobb County grand jury indicted Crawford on several charges, including malice murder and felony murder. After a jury trial in March 2022, Crawford was found guilty on all counts except theft by taking. He was sentenced to life without parole for malice murder and received a consecutive five-year sentence for possession of a firearm during the commission of a felony. Crawford filed a motion for a new trial, which was amended and heard in 2023, but the Cobb County Superior Court denied the motion. Crawford then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Crawford’s claims, including alleged errors in the admission of character evidence, hearsay testimony, lay opinion testimony, and cumulative error. The Court held that Crawford failed to demonstrate plain error or prejudice affecting the outcome of his trial. The Court found that any errors in admitting certain evidence were harmless given the strong evidence of guilt and that the cumulative effect of any errors did not deprive Crawford of a fundamentally fair trial. The Supreme Court of Georgia affirmed Crawford’s convictions and sentences. View "Crawford v. State" on Justia Law

On the night of March 10, 2020, Donnell Graham was fatally shot as he left the fast-food restaurant where he worked in Richmond County, Georgia. Prior to the shooting, Kenneth Green had threatened Graham during a phone call, stating he knew where Graham worked and when he finished his shift. On the night of the incident, Kenneth arranged for Ashley Jones to drive him to pick up Kendrick Green (the appellant) and Torjae Tanksley. Jones testified that Kenneth discussed a plan with Green and Tanksley, who both indicated their readiness. Surveillance footage and eyewitness testimony placed Green and Tanksley at the scene, and after the shooting, both were seen fleeing. Jones further testified that after the shooting, Kenneth asked Green and Tanksley if they had “handled that,” to which both replied affirmatively.A Richmond County grand jury indicted Green, Kenneth, Tanksley, and Jones for malice murder, felony murder predicated on aggravated assault, and possession of a firearm during the commission of a felony. Green, Kenneth, and Tanksley were jointly tried before a jury in October 2023, with Jones testifying against them under an immunity agreement. The jury convicted Green of felony murder and possession of a firearm, but acquitted him of malice murder. The trial judge sentenced Green to life without parole for felony murder and a consecutive five-year term for the firearm charge. Green filed a motion for new trial, which was denied by the Superior Court of Richmond County.The Supreme Court of Georgia reviewed Green’s appeal, in which he argued that the evidence was wholly circumstantial and insufficient under OCGA § 24-14-6. The Court held that the statute did not apply because the State presented direct evidence, including Green’s own admissions as testified to by Jones. The Supreme Court of Georgia affirmed Green’s convictions. View "Green v. State" on Justia Law

On October 28, 2015, two high school students, Darious Anderson and Stanley Winston, attempted to sell a revolver with the help of 17-year-old Spencer Robinson. After failing to find a buyer, the three walked through a neighborhood shortcut. There, Robinson asked to hold the gun, then pointed it at Anderson and Winston, declaring he was taking it. He told them to run before he started shooting, and as they fled, Robinson fired multiple shots, striking Anderson, who later died from his injuries. Winston initially gave police a false account but later identified Robinson as the shooter. Robinson was apprehended after fleeing from police and gave inconsistent statements, ultimately claiming Winston accidentally fired the gun.A DeKalb County grand jury indicted Robinson for malice murder, felony murder, aggravated assault (against both Anderson and Winston), and firearm possession during the commission of a felony. At trial in the Superior Court of DeKalb County, the jury found Robinson guilty of all counts except malice murder. He was sentenced to life imprisonment for felony murder, with additional consecutive sentences for aggravated assault and firearm possession. Robinson’s motion for a new trial was denied.The Supreme Court of Georgia reviewed Robinson’s appeal, in which he argued that the evidence was insufficient for his conviction for aggravated assault against Winston, that the trial court erred by not instructing the jury on accomplice corroboration, that his trial counsel was ineffective in several respects, and that cumulative errors warranted a new trial. The Court held that the evidence was sufficient, the trial court did not plainly err in its jury instructions, and that any possible deficiency by trial counsel did not prejudice Robinson’s defense. The Court also found no cumulative prejudice requiring a new trial. Accordingly, the Supreme Court of Georgia affirmed Robinson’s convictions and sentences. View "Robinson v. State" on Justia Law

A woman’s body was discovered inside a plastic container on the side of a Georgia interstate in January 2022. The victim was identified as Myra Smith Parlier. The investigation revealed that she died from asphyxia, with evidence indicating she was strangled with a dog leash and suffocated with a trash bag. Items found at her home matched those used in the concealment of her body. Jquantae Jester and his girlfriend, who had been staying at Parlier’s house, were linked to the crime through surveillance footage, use of Parlier’s financial cards, and possession of her belongings. Jester ultimately confessed to killing Parlier after confronting her about a sold shotgun, describing in detail how he strangled and suffocated her, then disposed of her body.A Fulton County grand jury indicted Jester for malice murder, felony murder, aggravated assault, and concealing the death of another. After a mistrial, a second trial resulted in Jester’s acquittal on malice murder but conviction on the remaining charges. The Superior Court of Fulton County sentenced him to life without parole for felony murder and a consecutive ten-year term for concealing the death. Jester’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 the admission of other-acts evidence, the lack of a jury instruction on confession corroboration, and alleged discovery violations. The court held that any error in admitting other-acts evidence was harmless due to overwhelming evidence of guilt and proper jury instructions. The omission of a confession corroboration instruction did not amount to plain error because the confession was amply corroborated. The court also found no plain error in admitting expert testimony despite alleged discovery violations. The convictions and sentences were affirmed. View "JESTER v. THE STATE" on Justia Law