Justia Criminal Law Opinion Summaries

In August 2014, Joandre Robbins was involved in the shooting death of Wayne Edwards. Robbins and Michael Thompson were indicted for malice murder and felony murder predicated on aggravated assault. Thompson pled guilty to a reduced charge and received probation, while Robbins was found guilty on both counts and sentenced to life in prison for malice murder. Robbins appealed, arguing that the trial court erred in excluding photographs of Edwards holding guns and that his trial counsel was ineffective.The Chatham County Superior Court handled the initial trial. Robbins was convicted by a jury, and the trial court sentenced him to life imprisonment. Robbins filed a motion for a new trial, which was denied after amendments and a hearing. Robbins then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Robbins's claims. The court held that even if the trial court erred in excluding the photographs, the error was harmless given the other evidence presented at trial. The court also found that Robbins's trial counsel was not constitutionally ineffective. The court reasoned that the decision not to object to the State's closing argument about parole was a strategic choice, and the jury instructions on self-defense and implied malice were appropriate. The court concluded that Robbins did not demonstrate that the outcome of the trial would have been different but for his counsel's actions. Consequently, the Supreme Court of Georgia affirmed Robbins's conviction and sentence. View "ROBBINS v. THE STATE" on Justia Law

David Dajuanta Wallace was convicted of felony murder and a firearm offense related to the shooting death of Darius Bottoms. Wallace argued that the evidence was insufficient, that his due process rights were violated by being required to wear a leg iron and prison clothing during the trial, and that he received ineffective assistance of counsel.A Fulton County grand jury indicted Wallace and two co-defendants for various crimes, including felony murder and gang activity. Wallace pled guilty to some charges and went to trial on others. The jury found him guilty of felony murder and a firearm offense. The trial court sentenced him to life in prison with the possibility of parole for felony murder and an additional five years for the firearm charge. Wallace's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case and found that the evidence was sufficient to support Wallace's convictions. The court held that the testimony of an accomplice was corroborated by other evidence, satisfying Georgia statutory law. Constitutionally, the evidence allowed the jury to find Wallace guilty as a party to the crimes rather than merely an accessory after the fact. The court also determined that any error related to Wallace wearing a leg iron was harmless beyond a reasonable doubt, given that the jury could not see the leg iron, Wallace used it strategically, and the strong evidence of his guilt.Regarding ineffective assistance of counsel, the court concluded that Wallace failed to show either deficiency or prejudice. The court affirmed Wallace's convictions and the trial court's rulings. View "WALLACE v. THE STATE" on Justia Law

A woman was convicted of felony murder, aggravated assault, aggravated battery, and cruelty to children following the death of her two-year-old foster child and the abuse of her four-year-old foster child. The crimes occurred in late 2015, and the woman and her husband were indicted multiple times, with the final indictment including 49 counts. The woman was found guilty on most counts and sentenced to life plus 40 years in prison. Her husband was also convicted on several counts and sentenced to 60 years in prison.The trial court granted a motion to suppress evidence from electronic devices, which was affirmed by the Supreme Court of Georgia. After a lengthy jury trial, the woman was found guilty on most charges. She filed a motion for a new trial, which was denied by the trial court. She then appealed to the Supreme Court of Georgia, arguing ineffective assistance of counsel and an unwaivable conflict of interest due to joint representation with her husband.The Supreme Court of Georgia affirmed the trial court's decision. The court held that the woman's trial counsel was not deficient for failing to request a jury instruction on justification, as the defense strategy focused on accident rather than justification. The court also found that any potential conflict of interest from joint representation was waivable and that the woman had knowingly, voluntarily, and intelligently waived her right to conflict-free counsel. The court concluded that the trial court did not abuse its discretion in denying the motion for a new trial. View "ROSENBAUM v. THE STATE" on Justia Law

Derek Burns was convicted of aggravated assault and other crimes following a jury trial in 2019. During his detention, Burns made three recorded phone calls to his attorney, Daniel Daugherty, on the jail’s phone line. Each call began with a recorded message stating that the call was being recorded. Despite Daugherty’s requests to stop the recording, the calls continued. The conversations primarily involved procedural matters about obtaining a bond and personal topics. At trial, Detective Lisa Wells testified that she had listened to these calls, leading Burns to move for a mistrial, arguing that his Sixth Amendment rights were violated.The trial court denied the motion for a mistrial, finding no harm to Burns as the calls did not contain privileged information. Burns filed a motion for a new trial, which was also denied. The Court of Appeals vacated the trial court’s ruling and remanded the case for further consideration of the Sixth Amendment issue. On remand, the trial court again denied the motion for a new trial, concluding that the calls were not protected by attorney-client privilege and did not contain any prejudicial information.The Supreme Court of Georgia reviewed the case and affirmed the Court of Appeals' decision. The court held that the jail calls were not protected by attorney-client privilege because they did not involve the giving or receiving of legal advice. The court concluded that the procedural and personal nature of the calls did not warrant privilege protection. Consequently, there was no violation of Burns’s Sixth Amendment right to counsel, and the judgment of the Court of Appeals was affirmed. View "BURNS v. THE STATE" on Justia Law

Darnell Cory Depriest was convicted of felony murder and other crimes related to the shooting death of his cousin, Ivan Lovejoy Williams. The incident occurred on October 11, 2019, at Depriest's residence. Depriest and Williams, who had been drinking, argued over money. Depriest retrieved a gun, and during a confrontation, the gun discharged, killing Williams. Witnesses Denise Williams and Tiffany Beatty provided accounts of the events, with Denise stating that Depriest aimed the gun at Williams before firing.A Newton County grand jury indicted Depriest on multiple charges, including malice murder and felony murder. At trial, Depriest was acquitted of malice murder but found guilty of felony murder and other charges. He was sentenced to life in prison for felony murder, with additional concurrent and consecutive sentences for other charges. Depriest's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case. Depriest argued that the evidence was insufficient to support his conviction and that his trial counsel was ineffective for not filing a motion for immunity from prosecution. He also contended that the trial court erred by not instructing the jury on the defense of others. The court held that the evidence was sufficient to sustain the conviction, as eyewitness testimony and other evidence supported the jury's verdict. The court found that trial counsel's decision not to file an immunity motion was reasonable and that Depriest was not prejudiced by this decision. Additionally, the court concluded that any error in not instructing the jury on the defense of others was harmless given the strong evidence against Depriest. The Supreme Court of Georgia affirmed the trial court's judgment. View "DEPRIEST v. THE STATE" on Justia Law

The case involves Sylvia Marie Najarro, who was convicted of felony murder and related crimes following the shooting death of Jamun El Winslow during a drug deal on February 5, 2020. Najarro, along with co-indictees Jaime Manuel Jimenez and Jayce Thayleen Villafana-Diaz, was indicted on multiple counts, including felony murder and aggravated assault. Najarro was tried alone and found guilty on several counts, leading to a life sentence plus an additional five years. Her motion for a new trial was denied, prompting this appeal.The trial court, the Superior Court of Gwinnett County, denied Najarro’s motion for a new trial after she argued that her trial counsel was constitutionally ineffective. Najarro contended that her counsel failed to object to certain pieces of evidence and did not adequately challenge the admission of body camera footage and a transcript of an interpreted interview. The trial court found that the decisions made by Najarro’s counsel were part of a reasonable trial strategy and did not constitute deficient performance.The Supreme Court of Georgia reviewed the case and affirmed the lower court’s decision. The court held that Najarro’s trial counsel’s actions were within the range of reasonable professional conduct. The court found that the counsel’s decisions not to object to certain evidence were strategic and aimed at mitigating the impact rather than being indicative of ineffective assistance. The court also determined that Najarro failed to demonstrate that any alleged deficiencies by her counsel resulted in prejudice that would have changed the outcome of the trial. Therefore, the Supreme Court of Georgia affirmed the judgment, concluding that Najarro did not meet the burden of proving ineffective assistance of counsel. View "NAJARRO v. THE STATE" on Justia Law

In 2018, Merrick Redding was convicted of felony murder and aggravated assault in connection with the death of Joseph Davis. The incident occurred during a barbecue where Redding, uninvited, approached Davis and struck him in the head, causing fatal injuries. Redding claimed self-defense, stating Davis provoked him, but witnesses testified that Davis did not physically provoke Redding before the fatal blow.Redding's case has been reviewed multiple times by the Supreme Court of Georgia. Initially, the trial court denied Redding's motion to dismiss based on a violation of his Sixth Amendment right to a speedy trial. The Supreme Court of Georgia vacated the trial court's judgment three times, each time remanding the case for proper factual findings and legal analysis regarding the speedy-trial claim. The trial court repeatedly denied the motion, leading to the current appeal.The Supreme Court of Georgia reviewed the trial court's denial of Redding's speedy-trial motion and found no abuse of discretion. The court applied the Barker-Doggett framework, considering the length of delay, reasons for delay, Redding's assertion of his right, and prejudice to Redding. The court concluded that the trial court correctly weighed these factors and did not err in its decision.Additionally, Redding challenged the trial court's admission of prior convictions for impeachment under Rule 609 and other-acts evidence under Rule 404(b). The Supreme Court of Georgia held that the trial court did not err in admitting the 2015 and 2009 convictions but assumed any error in admitting the 2007 conviction was harmless. The court also found that any error in admitting the other-acts evidence was harmless given the strong evidence against Redding. Consequently, the Supreme Court of Georgia affirmed the trial court's judgment. View "REDDING v. THE STATE" on Justia Law

In this case, the appellant was convicted of malice murder, arson in the first degree, and a violation of the Street Gang Terrorism and Prevention Act in connection with the shooting death of Quincy Suggs. The incident occurred on September 16, 2014, when Suggs visited a house occupied by prostitutes and gang members. The appellant, along with other co-defendants, was involved in a plan to rob Suggs, which resulted in Suggs being shot and killed. The house was later set on fire to cover up the crime.The case was initially reviewed by a Clayton County grand jury, which charged the appellant and his co-defendants with multiple offenses, including malice murder and arson. One co-defendant, Lofton, pled guilty to voluntary manslaughter and testified against the others. The appellant and two co-defendants were tried jointly before a jury, which found the appellant guilty of several charges, including malice murder and arson. The trial court sentenced the appellant to life without parole for malice murder and additional consecutive prison terms for the other charges. The appellant's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case and affirmed the appellant's convictions. The court held that the trial evidence was constitutionally sufficient to support the convictions for malice murder, arson, and the Gang Act violation. The court also rejected the appellant's claims of trial court error, prosecutorial misconduct, and ineffective assistance of counsel. The court found that the trial court did not abuse its discretion in admitting certain evidence and that the appellant's rights were not violated by the prosecutor's conduct or the trial court's handling of a sleeping juror. The court also concluded that there was no immunity agreement with a key witness, and thus no Brady violation occurred. View "PIERCE v. THE STATE" on Justia Law

In September 2019, the appellant was involved in a shooting that resulted in the death of Cameron Johnson. The appellant was romantically involved with Andrea Stanek, who had an on-again, off-again relationship with Johnson. On the night of the incident, after a walk to resolve tensions, the appellant shot Johnson in the chest. The appellant was charged with malice murder, two counts of felony murder, aggravated assault, and firearm-related offenses. He pleaded guilty to malice murder in October 2021 and was sentenced to life in prison with the possibility of parole after 30 years. The remaining charges were dismissed.The Glynn County Superior Court accepted the guilty plea and sentenced the appellant accordingly. The appellant filed a motion to withdraw his guilty plea, claiming ineffective assistance of counsel, specifically that his counsel failed to inform him about the 30-year parole eligibility requirement. The trial court denied this motion in July 2022, finding no deficiency in counsel’s performance. The appellant's subsequent motion to vacate the order was granted for procedural reasons, allowing him to file a timely appeal.The Supreme Court of Georgia reviewed the case and affirmed the trial court's decision. The court found that the appellant's counsel had adequately informed him about the parole consequences of his plea. The court noted that the trial court was entitled to credit the testimony of the appellant’s counsel over the appellant’s claims. The Supreme Court held that there was no abuse of discretion in the trial court’s denial of the motion to withdraw the guilty plea, as the appellant failed to demonstrate that his counsel’s performance was deficient. View "GOODWIN v. THE STATE" on Justia Law

In this case, the defendant, Gallegos-Munoz, was arrested after his girlfriend’s 12-year-old daughter, J.R., accused him of sexual misconduct, including rape and molestation. Before trial, Gallegos-Munoz sought to introduce evidence that J.R. had previously made false accusations of sexual abuse against her biological father. The trial court held a hearing and determined that there was no reasonable probability that J.R.’s prior accusation was false, thus excluding the evidence.The trial court denied Gallegos-Munoz’s motion for a new trial, which argued that under the precedent set by State v. Burns, the prior-accusation evidence should have been admitted under OCGA § 24-4-403 (Rule 403). The Court of Appeals affirmed the trial court’s decision, relying on the outdated probable-falsity threshold test from Smith v. State, which required a trial court to find a reasonable probability of falsity before admitting such evidence.The Supreme Court of Georgia reviewed the case and clarified that the 2013 Evidence Code governs the admissibility of prior-accusation evidence, not the outdated probable-falsity threshold test. The Court held that the rules set forth in the 2013 Evidence Code, including Rule 403, should be applied to determine the admissibility of such evidence. The Court vacated the judgment of the Court of Appeals and directed it to vacate the trial court’s ruling and remand the case for reconsideration under the applicable evidentiary standards. View "GALLEGOS-MUNOZ v. THE STATE" on Justia Law