Justia Criminal Law Opinion Summaries

Charvez Ryals was convicted of malice murder and other crimes related to the beating and fatal shooting of Daniel Wise. The incident occurred on March 10, 2018, in DeKalb County, Georgia. Ryals and his girlfriend, Regina Welch, had a history of domestic violence involving Wise, who was Regina's ex-boyfriend and the father of her three children. On the night before the murder, Wise confronted Regina and Ryals, demanding money and threatening them. The next morning, Wise returned to Regina's apartment, leading to a confrontation where Ryals shot Wise multiple times, resulting in his death.The case was initially tried in the Superior Court of DeKalb County, where a jury found Ryals guilty on all counts, including malice murder, felony murder, aggravated assault, cruelty to children, and firearm possession. The trial court sentenced Ryals to life in prison for malice murder, along with additional concurrent and consecutive sentences for the other charges. Ryals filed a motion for a new trial, which was denied by the trial court in March 2024.The Supreme Court of Georgia reviewed the case, focusing on Ryals' claims of ineffective assistance of counsel. Ryals argued that his trial counsel failed to subpoena a key witness, obtain phone records, introduce the criminal histories of Wise and another victim, and request a jury charge on voluntary manslaughter. The court found that these claims did not demonstrate deficient performance or resulting prejudice. The court held that the decisions made by Ryals' counsel were reasonable and strategic, and that any potential deficiencies did not affect the outcome of the trial. Consequently, the Supreme Court of Georgia affirmed the lower court's judgment, upholding Ryals' convictions and sentences. View "RYALS v. THE STATE" on Justia Law

Yathomas Riley was convicted of malice murder and other crimes related to the shooting death of his wife, Dr. Lisa Marie Riley, in the presence of their infant son. The crimes occurred on June 14 and July 9, 2015. Riley was indicted on multiple counts, including malice murder, felony murder, and aggravated assault. After a jury trial, Riley was found guilty on all counts and sentenced to life in prison without parole, along with additional consecutive and concurrent prison terms for other charges.Riley filed a motion for a new trial, which was denied by the trial court. He then appealed to the Court of Appeals, which transferred the case to the Supreme Court of Georgia. The Supreme Court remanded the case to the trial court to determine if Riley knowingly and voluntarily chose to represent himself on appeal. The trial court confirmed this, and the case was resubmitted to the Supreme Court.The Supreme Court of Georgia reviewed Riley's claims, including the trial court's decision to allow the lead investigator to remain in the courtroom, the presentation of allegedly false evidence, and claims of ineffective assistance of counsel. The court found no abuse of discretion in allowing the investigator to stay, as he was the State's chief investigative agent. Riley's claims about false evidence and perjured testimony were either not preserved for appeal or lacked supporting evidence. The court also found that Riley failed to demonstrate that his trial counsel's performance was deficient or that any alleged deficiencies prejudiced his defense.Riley's claim that his trial counsel conceded guilt in violation of McCoy v. Louisiana was also rejected. The court concluded that counsel did not concede guilt but rather argued alternative theories to support acquittal, which did not violate Riley's Sixth Amendment rights. The Supreme Court of Georgia affirmed Riley's convictions and sentences. View "RILEY v. THE STATE" on Justia Law

Brendan Riley was charged and convicted of murder and other crimes related to the shooting death of Glentis Wheeler. The State appealed the trial court's decision to grant Riley's amended motion for a new trial on the grounds of ineffective assistance of counsel, except for one count. Riley argued that his trial counsel was ineffective for not challenging the charging document, which he claimed was ambiguous and could have led to the dismissal of most charges if a general demurrer had been filed.The trial court found that the charging document did not meet the statutory requirements for an indictment and instead met the requirements of an accusation. Since certain crimes Riley was charged with could not be brought by accusation, the trial court ruled that his trial counsel was deficient for not challenging the document, resulting in prejudice to Riley. Consequently, the trial court granted Riley a new trial for most counts but did not address other arguments in his motion for a new trial.The Supreme Court of Georgia reviewed the case and determined that the charging document, while ambiguous, contained indications that it could be considered an indictment. The court found no binding precedent that would have required the trial court to dismiss the charges if a general demurrer had been filed. Therefore, the court concluded that Riley's trial counsel did not perform deficiently by failing to challenge the document. The Supreme Court of Georgia reversed the trial court's decision to grant a new trial for most counts and remanded the case for consideration of the remaining arguments in Riley's amended motion for a new trial. View "THE STATE v. RILEY" on Justia Law

Emmanuel Harris was involved in a fatal altercation with his girlfriend, Jordan Gooch, on September 14, 2021, during which he stabbed and killed her. Harris claimed self-defense, stating that Gooch attacked him with a knife. He was subsequently convicted of malice murder, felony murder, aggravated assault, and possession of a knife during the commission of a felony. The trial court sentenced him to life with the possibility of parole for malice murder and an additional five years for the knife possession charge. The aggravated assault charge was merged, and the felony murder charge was vacated.Harris appealed, arguing that the trial court erred by admitting evidence of a 2017 aggravated battery against his ex-girlfriend, C.A. The trial court had allowed this evidence to show Harris's motive to control his partners with violence and to demonstrate that the stabbing was not accidental. The evidence included detailed testimony from C.A. and graphic photos of her injuries. Harris's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case and found that the trial court abused its discretion by admitting the evidence of the 2017 battery. The court held that the evidence was improperly used to show Harris's bad character and propensity for violence, which is not permissible under Rule 404(b) of the Evidence Code. The court determined that the error was not harmless, as the prejudicial impact of the evidence likely influenced the jury's verdict. Consequently, the Supreme Court of Georgia reversed Harris's convictions but noted that the evidence was sufficient to authorize his convictions, allowing for the possibility of a retrial. View "Harris v. State" on Justia Law

The appellant was convicted of malice murder and other charges related to the shooting death of Taurus Thurmond. Thurmond, known for helping previously incarcerated individuals, had bailed the appellant out of jail and allowed him to live with him. They began a romantic relationship, but Thurmond expressed to his sister that he felt used and planned to end the relationship. The next day, Thurmond was found dead with three gunshot wounds to his head. The appellant was found in possession of Thurmond's vehicle, firearm, and other belongings, and had cut off his ankle monitor shortly after the murder.The trial court sentenced the appellant to life in prison without the possibility of parole for malice murder, along with additional consecutive sentences for other charges. The appellant filed a motion for a new trial, which was denied by the trial court. The appellant then appealed to the Supreme Court of Georgia, arguing that the evidence was insufficient to support his malice murder conviction and that his trial counsel was ineffective.The Supreme Court of Georgia reviewed the case and found that the evidence presented at trial was sufficient to support the malice murder conviction. The court noted that the appellant had threatened to kill Thurmond, was within earshot when Thurmond expressed his intention to end the relationship, and fled the scene after the murder. The court also found that the appellant's trial counsel was not ineffective for failing to object to the repeated showing of crime scene photographs or to certain testimony about the appellant's criminal past. The court concluded that there was no reasonable probability that the outcome of the trial would have been different if the objections had been made. The Supreme Court of Georgia affirmed the trial court's judgment. View "GUYTON v. THE STATE" on Justia Law

Terry Griffin was convicted of malice murder and other crimes related to the shooting death of her boyfriend, Wesley Hudson, in their shared apartment. Griffin was present at the scene and arrested immediately. During the trial, her counsel initially pursued a self-defense strategy but later shifted to arguing for a lesser charge of voluntary manslaughter after Griffin decided not to testify. The jury found Griffin guilty on all counts, including malice murder and felony murder.Griffin filed a motion for a new trial, arguing that her trial counsel violated her Sixth Amendment rights by abandoning her self-defense claim in favor of voluntary manslaughter without her consent, citing McCoy v. Louisiana. The trial court denied her motion, concluding that Griffin had not shown an "intransigent and unambiguous objection" to her counsel's strategy shift and that her counsel did not concede her guilt to the charges.The Supreme Court of Georgia reviewed the case and affirmed the lower court's decision. The court held that Griffin's claim under McCoy failed because she did not make a clear and persistent objection to her counsel's strategy, as required by McCoy. The court noted that Griffin's plea of "not guilty" and her counsel's initial self-defense argument did not amount to the type of "vociferous insistence" and "adamant objection" seen in McCoy. Therefore, the court concluded that Griffin's Sixth Amendment rights were not violated, and her conviction was upheld. View "GRIFFIN v. THE STATE" on Justia Law

Anthony Gates was charged with malice murder and other crimes related to the shooting death of Ronald Hammock. The incident occurred at a gas station where Hammock threatened and struck Gates, who then shot Hammock as he was turning to flee. Gates claimed he acted in self-defense, fearing for his life.The trial court granted Gates immunity and dismissed the charges, concluding that Gates reasonably believed the shooting was necessary for self-defense. The State appealed, arguing that surveillance video showed Hammock was fleeing, and thus Gates was not reasonably defending himself.The Supreme Court of Georgia reviewed the case and affirmed the trial court's decision. The court held that there was evidence to support the trial court's conclusion that Gates reasonably believed the use of force was necessary to prevent death or great bodily injury. The court emphasized that the trial court's factual findings and credibility determinations should be accepted if supported by any evidence. The court noted that the events transpired quickly, and Gates began firing immediately after being struck, which could reasonably be seen as self-defense. The court also highlighted that the State's frame-by-frame analysis of the video did not reflect the realities of the situation as it occurred. Therefore, the trial court's ruling that Gates was entitled to immunity from prosecution was upheld. View "THE STATE v. GATES" on Justia Law

Deangelo Tucker was convicted of murder and other charges related to the shootings of Nathaniel Lowe, Rondelrick Dukes, and Leonard Guffie, resulting in Lowe's death. The crimes occurred on November 16, 2014. Tucker was indicted on multiple counts, including malice murder, felony murder, aggravated assault, burglary, and possession of a firearm during the commission of a felony. A jury found him guilty on all counts, and he was sentenced to life in prison for malice murder, with additional consecutive and concurrent sentences for other charges. Tucker filed a motion for a new trial, which was denied, leading to his appeal.The trial court admitted evidence about the content of text messages allegedly sent by Tucker, despite the messages themselves not being introduced. Tucker's trial counsel did not object to this evidence, so the appellate court reviewed for plain error and found none, as the original messages were lost, and there was no bad faith by the State. Tucker also argued that the trial court erred by not charging the jury on justification, but the appellate court found no error, as there was no evidence of imminent danger to support such a charge.The Supreme Court of Georgia reviewed the case and found that the evidence was sufficient to support Tucker's convictions. The court also addressed Tucker's claims of trial court errors, including the admission of prejudicial evidence and the failure to charge the jury on justification. The court found no plain error in these claims. However, the court identified an error in the sentencing, where the trial court incorrectly merged the aggravated assault count related to Dukes with the felony murder count. The Supreme Court of Georgia affirmed Tucker's convictions in part, vacated the sentence on the aggravated assault count related to Lowe, and remanded the case for resentencing on the aggravated assault count related to Dukes. View "TUCKER v. THE STATE" on Justia Law

In this case, the defendant was indicted for multiple offenses, including burglary and drug-related charges. He entered a guilty plea to most charges and was sentenced to ten years, with one year in confinement and the remainder on probation. Later, the State alleged that he violated his probation by committing a new offense, leading to his arrest. The defendant filed a motion to terminate his probation, arguing that his probation should have automatically terminated under a retroactive statute, OCGA § 17-10-1 (a) (1) (B), which mandates early termination of probation under certain conditions.The trial court denied the motion, finding that the statute's procedural requirements were not met, specifically that the Department of Community Supervision (DCS) did not provide the required notice to the court and the prosecuting attorney. The trial court also determined that terminating the defendant's probation would not be in the best interest of justice and society.The Court of Appeals affirmed the trial court's decision, concluding that the notice requirement in the statute was directory rather than mandatory. The appellate court held that even if DCS failed to comply with the notice requirement, the termination of probation was not automatic, and the trial court retained discretion in deciding whether to terminate probation.The Supreme Court of Georgia reviewed the case and determined that the notice requirement in OCGA § 17-10-1 (a) (1) (B) is mandatory. However, the Court also held that DCS's failure to provide the required notice does not result in the automatic termination of probation. The trial court retains discretion to decide whether to terminate probation, considering the best interest of justice and the welfare of society. The Supreme Court affirmed the judgment of the Court of Appeals, albeit for different reasons. View "CLARK v. THE STATE" on Justia Law

Police executed a search warrant at Md Nazmul Islam's business and seized Delta-8 THC gummies, among other items. Islam was charged with possession of a Schedule I controlled substance with intent to distribute. He filed a motion under OCGA § 17-5-30 to exclude the seized property as evidence and to have it returned. The trial court granted the motion, finding the seizure unlawful and ordering the return of all seized property.The State appealed to the Court of Appeals, citing OCGA § 5-7-1 (a) (4), which allows appeals from orders excluding evidence on the grounds of unlawful seizure. However, the Court of Appeals dismissed the appeal, stating that the trial court's order did not explicitly exclude any evidence, only ordered the return of the property.The Supreme Court of Georgia reviewed the case to determine if the Court of Appeals correctly dismissed the State's appeal. The Supreme Court reversed the decision, holding that an order granting a motion under OCGA § 17-5-30 inherently excludes evidence by operation of law, even if not explicitly stated. Therefore, the trial court's order was indeed an order "excluding evidence illegally seized," and the State was authorized to appeal under OCGA § 5-7-1 (a) (4). The case was remanded to the Court of Appeals for consideration of the merits of the State's appeal. View "THE STATE v. ISLAM" on Justia Law