Justia Criminal Law Opinion Summaries

Bryan Miller was convicted by a jury of the malice murder of his wife, Gracie Miller, and the aggravated assault of her niece, Shamone Morris, after shooting them multiple times. The crimes occurred on May 18, 2021, and Miller was indicted on several counts, including malice murder and aggravated assault. He was sentenced to life without parole for the malice murder and an additional 30 years for other charges. Miller filed a motion for a new trial, which was denied by the trial court.Miller appealed to the Supreme Court of Georgia, arguing that the trial court abused its discretion by admitting evidence of two prior incidents involving his wife under OCGA § 24-4-404 (b). He claimed that the evidence was irrelevant due to his self-defense claim, that a plea of nolo contendere was insufficient to prove his involvement in one incident, and that the court failed to rule on the admissibility of the other acts concerning the assault on Morris.The Supreme Court of Georgia affirmed the trial court's decision. The court found that the prior incidents were relevant to show motive and the nature of the relationship between Miller and Gracie, which was pertinent to countering Miller's self-defense claim. The court also determined that the probative value of the evidence was not substantially outweighed by its prejudicial effect. Additionally, the court held that there was sufficient proof for a jury to find by a preponderance of the evidence that Miller committed the prior acts. The court also concluded that any error in admitting the evidence concerning the assault on Morris did not affect Miller's substantial rights, given the strong evidence against him and the limiting instructions provided to the jury. View "Miller v. State" on Justia Law

Prentice Baker and Verlaine Laguerre were convicted of malice murder and possession of a firearm during the commission of a felony for the shooting death of Matthew Hardeman. The evidence showed that Hardeman and Laguerre had a fistfight earlier in the day, which Hardeman won. Later, Laguerre returned with Baker and others to Hardeman’s neighborhood, where they encountered Hardeman and shot him multiple times, resulting in his death.A Fulton County grand jury indicted Baker and Laguerre on multiple counts, including malice murder and firearm possession. Their first trial ended in a mistrial, but a second joint trial in April 2018 resulted in guilty verdicts on all counts. Both defendants were sentenced to life in prison for malice murder and an additional five years for firearm possession. Their motions for a new trial were denied by the trial court in March 2022, leading to their appeals.The Supreme Court of Georgia reviewed the case and found no plain error in the trial court’s failure to instruct the jury on accomplice corroboration, as the evidence did not clearly indicate that Ellis was an accomplice. The court also found sufficient evidence to support Baker’s convictions, including Ellis’s identification of Baker as one of the shooters. Laguerre’s claim of ineffective assistance of counsel was rejected because his counsel’s decision not to object to certain testimony was deemed a reasonable strategic choice. Finally, the court dismissed Laguerre’s claim of cumulative error due to the lack of any established errors. The Supreme Court of Georgia affirmed the convictions and sentences of both Baker and Laguerre. View "BAKER v. THE STATE" on Justia Law

In November 2018, four defendants were convicted of various crimes related to two separate incidents. Jordan Campbell and Roderick Parrish were convicted of felony murder and other charges related to the death of Rebecca Foley in January 2013. Shacqeal Sanders and Henry Speaks were convicted of malice murder and other charges related to the death of James Pastures and the aggravated assault of Maurice Harris in January 2015. All four were also convicted of gang-related charges.The case was initially tried in October 2018, but a mistrial was declared after a juror was threatened. The retrial took place from October to November 2018. The jury found Campbell and Parrish guilty on all counts except malice murder and related gang charges. Sanders was found guilty on all counts except criminal attempt to commit a felony and two gang violations. Speaks was found guilty on all counts except criminal attempt to commit a felony, one count of aggravated assault, two counts of firearm possession during a felony, and three gang counts. The trial court sentenced each defendant to life without parole plus additional years for other counts.The Supreme Court of Georgia reviewed the case. The court affirmed the convictions, holding that the trial court did not abuse its discretion in denying the motion to sever the trials of the defendants and counts related to the two murders. The court also found that the trial court erred in admitting evidence of juror intimidation and in giving a deliberate ignorance instruction, but these errors were deemed harmless. The court concluded that the evidence was sufficient to support the convictions and that the trial court did not err in disqualifying Sanders’s counsel or in its jury instructions. The cumulative effect of the errors did not affect the jury’s verdicts. View "CAMPBELL v. THE STATE" on Justia Law

Alfred Moore was convicted in 2016 of first-degree burglary and other crimes, resulting in a total sentence of 45 years. On direct appeal, the Court of Appeals affirmed his convictions. Moore then filed a habeas corpus petition, later amended, arguing that his appellate counsel was ineffective for not claiming that his trial counsel was ineffective for failing to challenge the first-degree burglary count in the indictment. Moore contended that the indictment did not allege an essential element of first-degree burglary, specifically that he entered a "dwelling house" or a building "designed for use as [a] dwelling."The habeas court denied Moore's petition, concluding that the indictment was sufficient because it referenced the first-degree burglary statute. Moore appealed to the Supreme Court of Georgia, which granted his application for a certificate of probable cause to appeal, focusing on whether the habeas court erred in its ruling.The Supreme Court of Georgia found that the indictment failed to allege all essential elements of first-degree burglary, as it only mentioned that Moore entered a "business." The court determined that trial counsel was ineffective for not filing a special demurrer to challenge the indictment. This failure was not a reasonable trial strategy, and it was reasonably probable that the outcome of the trial would have been different if the indictment had been challenged. The court also found that appellate counsel was ineffective for not raising this issue on appeal.The Supreme Court of Georgia reversed the habeas court's denial of relief regarding Moore's first-degree burglary conviction and remanded the case with directions to vacate that conviction and grant appropriate relief. View "MOORE v. WHITE" on Justia Law

Andy Espinosa pleaded guilty to the malice murder of Zachary Mejia and other related offenses. Espinosa was living with his girlfriend and her four children, including Zachary. On December 8, 2020, Espinosa and Zachary had a physical altercation, which left Espinosa feeling humiliated. The next day, Espinosa searched online about what it feels like to murder someone. Later that day, he returned home, grabbed a knife, and fatally stabbed Zachary. Espinosa called 9-1-1 and was arrested. He later claimed he was overtaken by a "demon" during the stabbing.Espinosa was indicted by a Chattooga County grand jury and pleaded guilty to all counts without a sentencing recommendation from the State. The trial court sentenced him to life without parole for malice murder, a consecutive five-year term for possession of a knife during the commission of a felony, and a concurrent 12-month term for cruelty to children in the third degree. Espinosa filed a motion to withdraw his guilty plea, arguing ineffective assistance of counsel for not advising him of an insanity defense.The Supreme Court of Georgia reviewed the case. Espinosa claimed his plea counsel was ineffective for not investigating his mental state and advising him of a potential insanity defense. Plea counsel testified that he did not see a viable defense and believed a plea was in Espinosa's best interest. The court found that counsel's performance was not deficient, as his strategic decisions were based on his professional judgment and experience. The court also noted that Espinosa did not provide evidence of past mental health issues or expert testimony supporting an insanity defense.The Supreme Court of Georgia affirmed the trial court's decision, concluding that there was no abuse of discretion in denying Espinosa's motion to withdraw his guilty plea. The court held that Espinosa failed to demonstrate that his counsel's performance was constitutionally deficient. View "Espinosa v. State" on Justia Law

In January 2015, Kristian Wipfel, along with Dennis Eason, Jr., Tevin Sams, Antonio Garvin, and Jeremy Jackson, confronted Dejad Williams over a drug dispute. The confrontation led to a shooting at Williams's apartment, resulting in the death of eight-year-old Jai’mel Anderson. Wipfel was indicted for malice murder, felony murder, aggravated assault, making terroristic threats, and firearm possession during a felony. At trial, Garvin and Jackson testified against Wipfel, Eason, and Sams. The jury found Wipfel guilty of all charges except making terroristic threats.The trial court sentenced Wipfel to life without parole for malice murder, 20 years for aggravated assault, and consecutive five-year terms for the firearm offenses. Wipfel's motion for a new trial was denied, and his subsequent appeal was dismissed due to procedural issues. After rectifying the notification issue, Wipfel filed a timely appeal.The Supreme Court of Georgia reviewed Wipfel's claim that the trial court erred by not instructing the jury on involuntary manslaughter as a lesser offense of malice murder. Wipfel argued that his actions amounted to reckless conduct rather than malice murder. The court applied the plain error review standard, which requires showing that the error was clear, affected the trial's outcome, and impacted the fairness of the proceedings.The court held that the trial court did not err in failing to give the involuntary manslaughter instruction sua sponte, as Wipfel did not request it. The court reaffirmed the rule from State v. Stonaker, which states that a trial court's failure to instruct on a lesser offense without a request is not error. Consequently, Wipfel's claim of plain error failed, and the court affirmed his conviction. View "WIPFEL v. THE STATE" on Justia Law

Denarius Harris was convicted of felony murder and a firearm charge in connection with the shooting death of Dallas Spruill. Harris claimed he acted in self-defense, but the jury rejected this claim. The incident occurred when Spruill, along with Christian Boss and Pamela Blue, was selling TVs around Atlanta. They met Harris at an apartment complex, where a confrontation ensued, resulting in Harris shooting Spruill. Witnesses provided differing accounts of the events, but all agreed that Harris shot Spruill.The Fulton County grand jury indicted Harris on multiple charges, including malice murder and felony murder. The jury found him guilty of felony murder predicated on aggravated assault, aggravated assault, and possession of a firearm during the commission of a felony, but acquitted him of other charges. Harris was sentenced to life in prison for felony murder and an additional five years for the firearm charge. His motion for a new trial was denied by the trial court, leading to this appeal.The Supreme Court of Georgia reviewed Harris's appeal, focusing on his claims regarding the trial court's jury instructions on self-defense. Harris argued that the instructions were erroneous and could have misled the jury. However, the Supreme Court found that the instructions were correct statements of the law and followed the pattern jury instructions. The court held that the instructions did not confuse the jury as Harris claimed and affirmed his convictions and sentence. The court also rejected Harris's argument that the instructions placed undue emphasis on the use of deadly force, finding no error in the trial court's explanation of self-defense. Thus, the Supreme Court of Georgia affirmed the judgment. View "HARRIS v. THE STATE" on Justia Law

In this case, the appellant was convicted of malice murder and other crimes related to the shooting death of a woman. The incident occurred on August 22, 2014, when the victim was found dead and burned at a city dump. Evidence linked the appellant, a police officer, to the crime through cell phone records, DNA, and ballistic tests. The appellant admitted to meeting the victim for sex but claimed the shooting was accidental during a struggle over a gun.The Fulton County grand jury indicted the appellant on multiple charges, including malice murder, felony murder, and aggravated assault. A jury trial held in October 2016 resulted in the appellant being found guilty on all counts. The trial court sentenced him to life in prison without parole for malice murder and additional consecutive sentences for other charges. The appellant's motion for a new trial was denied by the trial court in November 2023.The Supreme Court of Georgia reviewed the case and addressed several claims of error by the appellant. The court concluded that any error in limiting the defense of accident to the aggravated assault charge was harmless, as the jury found the appellant guilty of malice murder, which required a finding of malicious intent. The court also found no error in the trial court's refusal to charge the jury on the defense of habitation, as there was no evidence the victim was entering or attacking the appellant's car when shot. Lastly, the court determined that the appellant failed to establish plain error regarding the jury instructions on justification. Consequently, the Supreme Court of Georgia affirmed the appellant's convictions. View "RANA v. THE STATE" on Justia Law

Michael Earl Summerville was convicted of felony murder in connection with the death of Martha West. On December 10, 2017, Summerville and West, who were romantic partners, visited their neighbor Johnny Clark. After an argument, Summerville returned to Clark’s home later that night, reporting that West had fallen in a nearby field. West was found deceased in the field, with evidence suggesting she had been struck by a vehicle. Summerville’s truck showed signs of a collision, and fibers consistent with West’s clothing were found on the truck. An autopsy revealed extensive injuries consistent with being struck by a motor vehicle.A Wilkes County grand jury indicted Summerville for malice murder, felony murder predicated on aggravated assault, and aggravated assault, family violence. He was found not guilty of malice murder but guilty of the remaining charges. The trial court sentenced him to life in prison for felony murder, with the aggravated assault charge merging for sentencing purposes. Summerville’s motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Summerville’s claims of ineffective assistance of counsel and trial court error. Summerville argued that his trial counsel was ineffective for not objecting to a comment in the State’s closing argument and that the trial court improperly limited cross-examination of a witness. The court held that the prosecutor’s comment during closing arguments was a permissible inference from the evidence, and thus, any objection would have been meritless. Additionally, the court found no abuse of discretion in limiting the cross-examination of the medical examiner, as Summerville failed to show that the examiner’s prior disciplinary action was probative of potential bias. The court affirmed the trial court’s judgment. View "Summerville v. State" on Justia Law

In March 2020, the appellant was convicted of malice murder and related charges for the shooting death of Mondavius Milan. The incident occurred on April 3, 2018, in Atlanta, involving a check fraud scheme with the appellant, Milan, and Jaleesia Mathis. On the morning of the shooting, the group, including Mathis's partner Japhar White, was in a car when an argument over missing money escalated. Witnesses testified that the appellant pulled out a gun, and after a struggle, Milan was shot. Both Mathis and White fled the scene, later identifying the appellant as the shooter. The appellant was arrested in Massachusetts and extradited to Georgia.The appellant was indicted by a Fulton County grand jury and found guilty on all counts by a jury. The trial court sentenced him to life in prison for malice murder and additional consecutive sentences for firearm charges. The appellant's motion for a new trial was denied by the trial court after an evidentiary hearing. The appellant then filed a timely notice of appeal.The Supreme Court of Georgia reviewed the case, focusing on two main contentions: ineffective assistance of counsel and insufficient evidence. The court held that the appellant's trial counsel was not ineffective for advising him not to testify, as the counsel's advice was based on reasonable strategic considerations. The court also found that the evidence, including corroborating testimony from accomplices and other witnesses, was sufficient to support the conviction. The court affirmed the trial court's judgment, concluding that the appellant's claims lacked merit. View "NABORS v. THE STATE" on Justia Law