Justia Criminal Law Opinion Summaries

In December 2017, a series of crimes occurred in Columbus, Georgia, involving Ladarius Travon Render and his co-defendants. Render was implicated in the theft of a Toyota Tacoma, the burglary and shooting of Kenneth Moore, and the aggravated assault and theft of a Buick Lucerne from the Williams family. Moore was shot during the burglary and later died from complications related to his injuries. Render and his co-defendants were indicted on multiple charges, including malice murder, felony murder, burglary, armed robbery, aggravated assault, and theft.The case was tried before a jury in the Superior Court of Muscogee County. Render moved for a directed verdict at the close of the State’s case, which was granted only for the armed robbery charge. The jury acquitted Render of malice murder and the theft of the Toyota Tacoma but found him guilty of felony murder, burglary, aggravated assault, and theft by receiving stolen property. Render was sentenced to life in prison with the possibility of parole for felony murder, along with additional consecutive and concurrent sentences for the other convictions. Render’s motion for a new trial was denied.The Supreme Court of Georgia reviewed the case. The court affirmed Render’s felony murder conviction but reversed his other convictions due to insufficient evidence under Georgia’s accomplice-corroboration statute. The court found that the only evidence linking Render to the non-murder charges came from an accomplice’s testimony, which was not adequately corroborated by independent evidence. The court also addressed and rejected Render’s claims of plain error regarding the admission of certain testimonies and ineffective assistance of counsel. The court concluded that the trial court did not commit plain error in admitting testimonies about video footage and statements made by co-defendants, and that Render’s trial counsel made a reasonable strategic decision not to move to sever the charges. View "RENDER v. THE STATE" on Justia Law

Napoleon Flowers was indicted for murder, aggravated assault, cruelty to children, and related charges after he fired multiple shots at Jim Johnson, fatally wounding him. The incident occurred on May 14, 2023, during an argument between Flowers and Johnson, with other adults and a child present. Flowers claimed self-defense, stating that Johnson was reaching for a shotgun when he began shooting. Flowers was arrested shortly after the incident, and he admitted to using a 9mm Taurus handgun in the shooting.The Dodge County grand jury indicted Flowers on multiple counts, including malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. Before the trial, the State sought to admit evidence of six other acts allegedly committed by Flowers under OCGA § 24-4-404(b). The trial court admitted one act as intrinsic to the shooting but excluded evidence of the other five acts. The State appealed the exclusion of these five acts under OCGA § 5-7-1(a)(5).The Supreme Court of Georgia reviewed the case and affirmed the trial court's decision to exclude the five other acts. The court held that the trial court did not abuse its discretion in excluding the evidence under Rule 404(b) and Rule 403. The court found that the other acts were not relevant to Flowers's intent, knowledge, absence of mistake or accident, identity, or motive, given his sole claim of self-defense. Additionally, the court determined that the probative value of the other acts was diminished by the availability of eyewitness testimony and Flowers's recorded statement, and that the danger of unfair prejudice substantially outweighed their probative value. View "THE STATE v. FLOWERS" on Justia Law

Roderick Watkins was convicted of malice murder and other crimes related to the March 14, 2012, shooting death of Ashley Clark and her unborn child. Watkins and Clark were in a romantic relationship that deteriorated over time, with Clark documenting physical, verbal, and emotional abuse in her diary. Clark became pregnant in late 2011, and despite Watkins's insistence on an abortion, she decided to keep the baby. On March 13, 2012, Clark wrote in her diary that Watkins planned to cause her to have a miscarriage. The next night, Watkins shot Clark, resulting in her death and the death of her unborn child.A Fulton County grand jury indicted Watkins on multiple charges, including murder and possession of cocaine. A jury found him guilty on all counts, and the trial court sentenced him to life in prison for murder and feticide, among other sentences for related charges. Watkins moved for a new trial, which was denied by the trial court. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the case and addressed several claims by Watkins. The court found that the trial court did not abuse its discretion in admitting Clark's diary entries under Rule 807, as they bore equivalent circumstantial guarantees of trustworthiness and were material and probative. The court also found no plain error in the admission of Watkins's pre-arrest silence or failure to come forward. However, the court concluded that the admission of testimony by a Georgia Bureau of Investigation analyst, who relayed the findings of a non-testifying analyst, violated the Confrontation Clause under Smith v. Arizona. Consequently, the court reversed Watkins's convictions for possession of cocaine and possession of a firearm during the commission of a felony predicated on possession of cocaine. The court affirmed the remaining convictions. View "Watkins v. State" on Justia Law

The appellant, Jamie Alexander Washington, was convicted of felony murder and related crimes connected to the aggravated assault of Desmond Carter and the shooting death of James Hawkins in Dougherty County. The crimes occurred on July 5, 2015. Washington, along with co-defendants Mylan Mahoney and Malcolm Bernard Offord, Jr., was indicted on October 1, 2015, and reindicted on February 8, 2017. Mahoney and Offord pled guilty and testified against Washington. Washington was tried before a jury in February 2020, found guilty, and sentenced to life in prison without parole for felony murder, with additional concurrent and consecutive sentences for other charges.Washington filed a motion for a new trial, which was denied by the trial court on March 11, 2024. He then appealed to the Supreme Court of Georgia, raising several claims of trial-court error and ineffective assistance of counsel.The Supreme Court of Georgia reviewed the case and found the evidence sufficient to support Washington's conviction for felony murder, rejecting his argument that the evidence was insufficient under Georgia’s accomplice-corroboration statute. The court also found no plain error in the trial court's questioning of a witness, which Washington claimed expressed an opinion on the evidence. Additionally, the court concluded that any error in allowing the State to cross-examine Washington about his criminal history was harmless given the strong evidence against him.Regarding ineffective assistance of counsel claims, the court determined that Washington's trial counsel was not deficient in failing to locate a witness, object to hearsay testimony, request an alibi instruction, or object to certain prosecutorial comments during closing arguments. The court also found no cumulative prejudice from the alleged errors and instances of ineffective assistance.The Supreme Court of Georgia affirmed Washington's convictions. View "WASHINGTON v. THE STATE" on Justia Law

In this case, Nemiyas Smith was convicted by a jury of murder, aggravated assault, and related charges for the shooting of Kornelius Favors and Constance McCier. The incident occurred on March 22, 2019, and Smith claimed self-defense. Smith was indicted on multiple counts, including malice murder, felony murder, aggravated assault, and possession of a firearm by a convicted felon. The trial took place in November 2021, and Smith was found guilty on all counts. He was sentenced to life in prison plus 25 years.Smith filed a motion for a new trial, which was denied by the trial court. He then appealed to the Supreme Court of Georgia, arguing ineffective assistance of counsel. Smith claimed his trial counsel failed to present an expert witness to establish that two different guns fired the bullets that killed Favors, failed to object to the State's improper closing argument regarding felony murder, and failed to object to allegedly false evidence and argument about his brother, Neddrick, being a defendant in another murder case.The Supreme Court of Georgia reviewed the case and affirmed the lower court's decision. The court held that Smith's trial counsel was not deficient in failing to present an expert witness, as the decision was a matter of trial strategy. The court also found that Smith's claim regarding the State's closing argument about felony murder was moot because his felony murder conviction was vacated by operation of law. Additionally, the court determined that trial counsel's decisions regarding Detective Casey's testimony about Neddrick were within the range of professional competence. Finally, the court concluded that any false testimony about Neddrick's involvement in another murder case was immaterial and did not affect the jury's judgment. View "SMITH v. THE STATE" on Justia Law

Jaylen Leverette was indicted along with three others for aggravated assault and felony murder related to a shooting incident on August 1, 2018, where a bystander was killed. Leverette filed a motion to suppress incriminating statements made during a custodial interview, arguing they were inadmissible under various legal grounds, including OCGA § 24-8-824, which excludes confessions induced by the slightest hope of benefit.The trial court granted Leverette’s motion to suppress, finding that his confession was induced by a hope of benefit. The court focused on statements made by Major Ralph Stuart during the interview, which suggested that Leverette would not be charged with the fatal shooting if he admitted his involvement. The court concluded that these statements constituted assurances that persuaded Leverette to confess.The Supreme Court of Georgia reviewed the case and concluded that the trial court erred in its decision. The court held that the statements made by Major Stuart did not constitute an impermissible hope of benefit under OCGA § 24-8-824. The court explained that the comments made by Stuart were not promises related to reduced criminal punishment but rather exhortations to tell the truth. The court emphasized that statements indicating that telling the truth would be beneficial or that lying would make things worse do not violate the statute.As a result, the Supreme Court of Georgia vacated the trial court’s order suppressing Leverette’s statements and remanded the case for further proceedings to consider Leverette’s other grounds for excluding his statements. View "THE STATE v. LEVERETTE" on Justia Law

Shamar Dequan Wilson was convicted for his involvement in the robbery and death of Rashawn Mays and the attempted armed robbery of Adrian Bennett. The crimes occurred on January 22, 2020. Wilson was indicted by a Lowndes County grand jury on April 30, 2021, and charged with felony murder, armed robbery, attempted armed robbery, and possession of a firearm during the commission of a felony. At his trial in January 2022, the jury found Wilson guilty on all counts. He was sentenced to life with the possibility of parole for felony murder, along with additional concurrent and consecutive sentences for the other charges. Wilson filed a motion for a new trial, which was denied, and subsequently appealed.Wilson's appeal focused on the sufficiency of the evidence for his convictions of attempted armed robbery and the associated possession of a firearm during the commission of a felony. He argued that the evidence did not prove his guilt beyond a reasonable doubt for these specific counts. The trial court had denied his motion for a new trial, leading to his appeal to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the case and found that the evidence was sufficient to support Wilson's convictions. The court noted that Bennett's testimony indicated Wilson pointed a gun at him and demanded money, which Bennett interpreted as a demand for his own money. Although Wilson did not take Bennett's wallet and phone, the court concluded that a reasonable jury could infer that Wilson's intent was to avoid being seen by Bennett. Therefore, the court affirmed Wilson's convictions for attempted armed robbery and possession of a firearm during the commission of a felony. The judgment was affirmed, and all justices concurred. View "WILSON v. THE STATE" on Justia Law

Hector Garcia-Solis was convicted of malice murder and other crimes related to the shooting death of Hall County Deputy Sheriff Blane Dixon on July 7, 2019. Garcia-Solis, along with co-defendants Brayan Cruz, Eric Velazquez, and London Clements, was involved in a series of burglaries and thefts leading up to the fatal shooting. The group stole vehicles and firearms, and during a police chase, Garcia-Solis shot and killed Deputy Dixon. Garcia-Solis was sentenced to life in prison without the possibility of parole, plus additional consecutive years for other charges.The case was initially reviewed by a Hall County grand jury, which indicted Garcia-Solis and his co-defendants on multiple counts, including malice murder, felony murder, aggravated assault, and various theft-related charges. Cruz pleaded guilty to some charges and testified for the State. Garcia-Solis, Velazquez, and Clements were tried together, and the jury found Garcia-Solis guilty on all counts. The trial court sentenced him to life without parole for malice murder and additional consecutive years for other charges. Garcia-Solis filed a motion for a new trial, which was denied, leading to his appeal to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the case and affirmed Garcia-Solis's convictions and sentences. The court held that the evidence was sufficient to support the malice murder conviction, as Garcia-Solis intentionally shot Deputy Dixon, demonstrating an "abandoned and malignant heart." The court also found no merit in Garcia-Solis's claim that the trial court erred in denying his motion for a change of venue due to pretrial publicity, as the jury selection process did not show actual prejudice. Lastly, the court upheld the life without parole sentence, noting that the trial court properly considered Garcia-Solis's age and the egregious nature of his crimes. View "GARCIA-SOLIS v. THE STATE" on Justia Law

Rondriques Brundage was convicted of felony murder and possession of a firearm during the commission of a felony for the shooting death of Rodrell Matthews. The incident occurred on July 10, 2018, and Brundage was indicted on multiple charges, including malice murder and aggravated assault. At trial, Brundage was found not guilty of malice murder, felony murder predicated on aggravated assault, and aggravated assault, but guilty of felony murder predicated on possession of a firearm by a convicted felon, possession of a firearm by a convicted felon, possession of a firearm during the commission of a felony, and concealing the death of another. He was sentenced to life without parole for felony murder, plus additional consecutive prison terms for the other charges.Brundage filed a motion for a new trial, which was denied except for the merger of the possession of a firearm by a convicted felon count into the felony murder count. He appealed, arguing that his trial counsel was ineffective for failing to object to the State's incorrect explanation of self-defense as it applied to felony murder predicated on felon-in-possession and for failing to request a jury charge on the defense of habitation.The Supreme Court of Georgia reviewed the case and agreed with Brundage that his trial counsel was deficient for not objecting to the State's incorrect explanation of self-defense. The court found that this deficiency prejudiced Brundage, as it was reasonably probable that an objection would have led to a different outcome regarding the felony murder and possession of a firearm during the commission of a felony charges. Consequently, the court reversed Brundage's convictions on those counts, allowing for the possibility of retrial. The court affirmed Brundage's conviction for concealing the death of another, which was not challenged on appeal. The case was remanded for further proceedings consistent with the court's opinion. View "BRUNDAGE v. THE STATE" on Justia Law

Raiem Singleton was convicted of malice murder and other crimes related to the shooting death of Luz Selene Velazquez and the aggravated assault of David Montes-Ponce. The crimes occurred on May 5, 2017, when Montes-Ponce and Velazquez arranged to buy a phone from a seller named "Tom Li" through a mobile app. When they met the seller at an apartment complex, the seller, accompanied by two other men, shot at Montes-Ponce's car, killing Velazquez. Montes-Ponce identified Singleton as the shooter.A DeKalb County grand jury indicted Singleton on multiple charges, including malice murder and aggravated assault. Following a jury trial, Singleton was found guilty on all counts and sentenced to life in prison for malice murder, with additional concurrent and suspended sentences for other charges. Singleton filed a motion for a new trial, which was denied by the trial court after a hearing.The Supreme Court of Georgia reviewed Singleton's appeal, where he argued that the trial court erred in denying his motion to suppress identification evidence from a photo lineup. The court employed a two-step process to evaluate the identification procedure, considering whether it was impermissibly suggestive and whether there was a substantial likelihood of irreparable misidentification. The court found that even if the lineup was suggestive, there was no substantial likelihood of misidentification due to Montes-Ponce's significant opportunity to view Singleton during the crime and his high degree of certainty in identifying Singleton.The Supreme Court of Georgia affirmed the trial court's decision, holding that the trial court did not abuse its discretion in admitting the identification evidence and denying Singleton's motion to suppress. View "SINGLETON v. THE STATE" on Justia Law