Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Georgia
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Willie Felix Thompson was convicted of malice murder and other crimes related to the shooting death of Felicia Sullivan. Thompson and Sullivan had a tumultuous relationship marked by several violent incidents. On April 19, 2021, Thompson returned to their shared residence to collect his belongings but ended up shooting Sullivan during an altercation. Thompson claimed self-defense, stating that Sullivan attacked him first. However, forensic evidence and witness testimonies contradicted his account.A Cobb County grand jury indicted Thompson on charges including malice murder and aggravated assault. During the trial, the jury found him guilty on all counts. The trial court sentenced him to life in prison without parole for malice murder and an additional five years for the weapons charge. Thompson's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case and upheld the convictions. The court found that the evidence presented at trial was sufficient to support the jury's verdict. The court also determined that the trial court did not err in its jury instructions regarding prior-bad-acts and prior-difficulties evidence. The Supreme Court concluded that Thompson failed to demonstrate any clear or obvious error in the jury instructions and affirmed the lower court's decision. View "THOMPSON v. THE STATE" on Justia Law

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Chrishon Siders was convicted of murder and other crimes related to the shooting death of Seine Yale Jackson. On January 6, 2016, Siders, along with Haleem Graham and Brantley Washington, drove to Jackson’s home to purchase drugs. Siders was identified near the scene by a witness, and Jackson was found dead shortly after. Evidence included cell phone data, surveillance footage, and witness testimony linking Siders and his co-defendants to the crime. Siders testified, denying involvement and claiming he was elsewhere during the murder.The Fulton County Superior Court held a joint trial for Siders, Graham, and Washington, resulting in guilty verdicts for all charges against Siders. He was sentenced to life in prison without parole for malice murder, with additional consecutive sentences for other charges. Siders filed a motion for a new trial, which was denied. He then sought an out-of-time appeal, which was initially granted but later vacated following a change in procedural law. Siders subsequently filed a habeas corpus petition, which was granted, allowing him to file an out-of-time appeal.The Supreme Court of Georgia reviewed the case and affirmed the lower court’s decision. The court held that the evidence was sufficient to support Siders' convictions, rejecting his claims of insufficient evidence and errors in the trial court’s handling of evidence and jury instructions. The court found no abuse of discretion in admitting social media posts and hearsay statements, and it determined that the trial court’s responses to jury questions and instructions on witness credibility were appropriate. The court concluded that Siders' arguments did not demonstrate any reversible error. View "SIDERS v. THE STATE" on Justia Law

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In October 2015, a jury found Dolonte Tedder guilty of malice murder and related crimes connected to the shooting death of Quleon Glass. The incident occurred on September 8, 2014, and Tedder, along with co-indictees Jacquavious Eggleston and Teandria Tabb, was indicted for various offenses. Tedder was tried alone and found guilty on all counts. He was sentenced to life in prison for malice murder, with additional concurrent and consecutive terms for other charges. Tedder filed a motion for a new trial, which was partially granted due to ineffective assistance of counsel. The case was remanded, and after further proceedings, the trial court denied the motion for a new trial.The Supreme Court of Georgia reviewed the case following the trial court's denial of Tedder's motion for a new trial. Tedder argued that the evidence was insufficient to sustain his convictions, that the trial court committed reversible errors, and that his trial counsel was constitutionally ineffective. The court found that the evidence presented at trial was sufficient to support Tedder's convictions for malice murder, aggravated assault, and possession of a firearm during the commission of a felony. The court also concluded that the evidence was sufficient to establish that Yung Fame was a criminal street gang and that Tedder was associated with it.The Supreme Court of Georgia affirmed the trial court's decision, holding that the trial court did not err in denying Tedder's motion for a directed verdict and that the evidence was sufficient to support his convictions. The court also found no error in the trial court's response to a jury question during deliberations and upheld the exclusion of juror affidavits under Rule 606(b). Finally, the court rejected Tedder's claims of ineffective assistance of counsel, concluding that his trial counsel's performance was not deficient and that Tedder failed to demonstrate prejudice. View "TEDDER v. THE STATE" on Justia Law

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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

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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

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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

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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

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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

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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

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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