Justia Criminal Law Opinion Summaries

In this Georgia Supreme Court case, the defendant, Darnell Rene Floyd, was convicted of felony murder predicated on possession of a firearm by a convicted felon and other related charges in connection to the shooting death of Telmo Ortiz. Floyd argued he was acting in self-defense during the incident. On appeal, Floyd's main contention was that his trial counsel was constitutionally ineffective due to their handling of the interplay between self-defense and possession of a firearm by a convicted felon.The Supreme Court of Georgia agreed with Floyd and reversed his conviction. The Court concluded that Floyd's trial counsel failed to request a jury instruction about self-defense under OCGA § 16-11-138, which provides that self-defense can be an absolute defense for a convicted felon in possession of a firearm. Additionally, the court determined Floyd's trial counsel didn't clearly explain that self-defense applied to felony murder based on felon-in-possession and agreed with the trial court's response to the jury's question, which didn't clarify the application of self-defense to felony murder and felon-in-possession.The court held that these failures constituted deficient performance by counsel and resulted in prejudice to Floyd's case. However, since the evidence against Floyd was constitutionally sufficient to authorize the conviction, he may be retried. The court also reversed Floyd's conviction for possession of a firearm during the commission of a felony, as it was only supported by the reversed felony murder conviction. View "FLOYD v. THE STATE" on Justia Law

In 2019, co-defendants Mark Kirkland and Kendrick Ogletree were found guilty of numerous offenses, including malice murder, related to the arson-related deaths of Deangelo Barbary and Debra Morris. The pair were indicted on charges of murder, felony murder, and arson in the first degree, with Ogletree also charged with conspiracy to commit arson and criminal solicitation. Both defendants contend that the trial court erred in various ways, including by admitting improper character evidence. The Supreme Court of Georgia reviewed the case and found that Kirkland failed to prove that the trial court abused its discretion in admitting certain evidence and that his trial counsel was ineffective. The court also concluded that the evidence was sufficient to support Ogletree’s convictions. As such, the court affirmed both Kirkland’s and Ogletree’s convictions. The Supreme Court noted that the trial court erred in its final instruction to the jury about the use of admitted evidence of other acts, but concluded that the error did not affect the outcome of the proceedings given the strong evidence of guilt presented by the State. View "KIRKLAND v. THE STATE" on Justia Law

Donald Berry Green appealed his sentence for felony murder and aggravated assault related to the shooting death of Andre Winter. He entered a guilty plea, but years later, began filing motions for an out-of-time appeal. Green argued that his guilty plea was involuntary and unintelligent because he wasn't expressly advised on the record of his right against self-incrimination, one of the three specific rights listed in "Boykin v. Alabama" (1969) that a defendant waives when entering a guilty plea. The Supreme Court of Georgia found that the record showed Green's plea was voluntary and intelligent, despite the absence of an express advisement of his right against self-incrimination. The Court overruled its previous decisions that adopted a "three Boykin rights" approach, which automatically reversed a guilty plea if the record didn't show the defendant was expressly informed about all three rights listed in "Boykin v. Alabama". The Court held that a guilty plea is valid if the record shows it was voluntary and intelligent, regardless of whether all three rights were explicitly conveyed to the defendant. Therefore, the Court affirmed Green's convictions. View "GREEN v. THE STATE" on Justia Law

In this case, appellant Austin Levi Payne appealed his convictions for felony murder and other crimes related to the death of one-year-old Journey Cowart. The Supreme Court of Georgia affirmed the lower court's decision. The court found that the evidence presented at trial was sufficient to support Payne's convictions. The court reasoned that since Payne and the victim's mother, Brandy Boyd, were the only caretakers of the child during the time the fatal injuries were inflicted, the jury could reasonably conclude that either Payne, Boyd, or both were responsible for the injuries. The court also refuted Payne's arguments regarding the exclusion of evidence about Boyd's drug use and the failure to give a requested jury charge on grave suspicion. Finally, the court dismissed Payne's claim of ineffective assistance of counsel, concluding that Payne failed to show that his trial counsel performed deficiently. View "PAYNE v. STATE" on Justia Law

In the case decided by the Supreme Court of Georgia, the appellant, Karonta Morrell, appealed his convictions related to the shooting death of Jonathan Lang. The appellant was found guilty of multiple charges including malice murder, felony murder, criminal attempt to murder, aggravated assault, possession of a firearm during the commission of a felony, and possession of a firearm by a convicted felon. He was sentenced to life in prison without the possibility of parole, along with several consecutive prison terms for other counts.On appeal, Morrell argued that the evidence was insufficient to support his convictions and that the record contained several deficiencies, preventing a full and fair appellate review. The court affirmed the trial court's decision, holding that the evidence was sufficient to support Morrell’s malice murder conviction. The court found that the jury could easily find that Morrell was present during the crime, as several eyewitnesses placed him there and his own statements also placed him there. Morrell’s argument that his actions were justified or that, at most, he was guilty only of voluntary manslaughter based on provocation was dismissed. The court explained that fighting is not the type of provocation that would support a voluntary manslaughter jury charge.Regarding Morrell's claim of an incomplete trial record, the court found no merit as all transcripts and exhibits at issue were included in the appellate record. Morrell's claim that periodic “indiscernible” notations made the record “incomplete” was dismissed as he cited no authority requiring court reporters to transcribe the contents of recordings admitted as exhibits. Therefore, the court held that Morrell failed to show how any deficiencies in the record have harmed him. View "MORRELL v. STATE" on Justia Law

In the case under review, the appellant, David Wallace Lee, was convicted of two counts of malice murder related to the shooting deaths of Meghan Bowen and James Harden. The appellant argued on several grounds, including insufficiency of evidence, trial court errors, and ineffective assistance of counsel.The Supreme Court of Georgia concluded that the evidence presented at trial was sufficient to support the appellant's convictions. The evidence demonstrated a history of abuse, jealousy, and threats by the appellant towards Bowen, which escalated in the months leading up to the murders. The appellant's claims of trial court errors were also rejected, as the court found no abuse of discretion in the admission of testimony regarding the appellant's possession of a gun similar to the murder weapon and found no actual conflict of interest necessitating the disqualification of an assistant district attorney.Further, the appellant's claims of ineffective assistance of counsel were also rejected. The court held that the appellant failed to demonstrate that his counsel’s performance was professionally deficient and that he suffered prejudice as a result.Therefore, the court affirmed the appellant's convictions and sentence. View "LEE v. STATE" on Justia Law

The defendant, Luis Vendrel, was convicted for malice murder and possession of a firearm during the commission of a felony in connection with the shooting death of Nova Jill Saffles. Vendrel appealed his convictions, arguing that he suffered a constructive denial of his right to counsel or otherwise received ineffective assistance of trial counsel. He claimed that his counsel failed to interview defense witnesses before trial, failed to prepare him to testify, and failed to conduct factual research or consult with experts to prepare to challenge the prosecution’s forensic evidence. The Supreme Court of Georgia found that Vendrel failed to establish that any of these alleged deficiencies in counsel's performance prejudiced his defense. Therefore, the court affirmed Vendrel's convictions. The court held that the defendant did not meet the stringent standard to raise a presumption of prejudice under United States v. Cronic, as he did not demonstrate that his counsel entirely failed to subject the State’s case to adversarial testing. Instead, the court applied the two-part Strickland test and found that Vendrel failed to show that his counsel's performance was constitutionally deficient or that this deficient performance prejudiced him. View "VENDREL v. STATE" on Justia Law

In this case, the appellant, Shomari Tahir Holmes, appealed his convictions for felony murder and other crimes related to the death of his 20-month-old son and for cruelty to children in the first degree against his son's three-year-old half-sister. The appellant was found guilty but mentally ill by a jury. On appeal, the appellant claimed that the trial court abused its discretion in admitting an audio recording of an interview conducted by a psychiatrist and expert witness for the State, and that the court erred by failing to instruct the jury on a verdict of “guilty but with intellectual disability.”The Supreme Court of Georgia rejected both of appellant’s claims and affirmed the convictions. The court held that the trial court did not abuse its discretion in admitting the audio recording of the interview. The court reasoned that the appellant put his mental condition at issue, and the recording only addressed the purpose of the interview and did not constitute an opinion or inference about appellant’s mental state at the time of the crime.Furthermore, the court held that the trial court did not err in failing to instruct the jury on a verdict of “guilty but with intellectual disability.” The court explained that the appellant's counsel initially requested the instruction but later withdrew the request at the charge conference. Under Georgia law, when a defendant requests a specific jury instruction at the outset of trial but later withdraws the request during the charge conference, the defendant has affirmatively waived any right to the charge. Therefore, the appellant's claim concerning the charge failed. View "HOLMES v. STATE" on Justia Law

In this case, the Supreme Court of Georgia was asked to review the conviction of Merrick Redding, who was found guilty of felony murder and aggravated assault in connection with the death of Joseph Davis. Redding appealed his conviction several times, arguing that his Sixth Amendment right to a speedy trial was violated. The Court had previously vacated the judgment and remanded the case back to the trial court for fact-finding and legal conclusions on the speedy trial issue. On remand, the trial court again denied Redding's speedy trial motion, leading to the current appeal.The Supreme Court of Georgia examined the trial court’s application of the four-factor test from Barker v. Wingo and Doggett v. United States to evaluate Redding's constitutional speedy trial claim. The factors are: the length of the delay, the reasons for the delay, the defendant's assertion of his right to a speedy trial, and prejudice to the defendant.In its analysis, the Court found that the trial court erred in weighing the length of delay and the reasons for delay as neutral. It should have weighed these factors against the State since the delay was uncommonly long and solely attributable to the State. The Court found no abuse of discretion in the trial court's decision to weigh neutrally the defendant's assertion of his right to a speedy trial and to weigh the prejudice factor heavily against Redding.Because the trial court misapplied the law and made factual errors, the Supreme Court of Georgia vacated the trial court's order denying Redding’s speedy-trial motion and again remanded the case for the trial court to resolve the speedy-trial claim. The Court noted that the trial court may still have discretion to deny Redding’s motion after properly weighing the factors. It did not address any other claims of error raised by Redding. View "REDDING v. STATE" on Justia Law

In 2018, Hassan Shareef Rashad was indicted for numerous charges including the malice murder of two-year-old Adrian Mitchell. The Supreme Court of Georgia upheld Rashad's conviction. The evidence presented at trial showed that Rashad, who was in a romantic relationship with Adrian's mother, Sydney Dean, was the only adult present when Adrian suffered fatal injuries. Witnesses reported observing concerning behavior between Rashad and Adrian, including verbal abuse and physical punishment. In October 2017, Adrian was taken to the hospital with a fractured leg, which doctors concluded was likely caused by non-accidental trauma. In April 2018, Adrian was found unresponsive and later died from what doctors concluded were non-accidental, significant force injuries. The Supreme Court of Georgia held that the evidence was sufficient to authorize a jury to find Rashad guilty beyond a reasonable doubt of the malice murder of Adrian. Rashad's claims of ineffective assistance of counsel were also rejected. View "RASHAD v. STATE" on Justia Law