Justia Criminal Law Opinion Summaries

In this case, the defendant and the victim lived in separate rooms at the same motel. The defendant testified that a dispute arose after he refused to sell marijuana to the victim’s girlfriend, leading to several tense encounters between the defendant and the victim. On the day of the incident, the defendant, armed with a gun, approached the victim’s room under the pretense of checking on him. An argument ensued, during which the defendant claimed to feel threatened by the victim, who was larger and allegedly aggressive with a broom. The defendant shot the victim multiple times, resulting in the victim’s death. A witness in the room described the conversation as initially calm but escalating, and testified to hearing gunshots and seeing the defendant leave. The defendant was later arrested, and the murder weapon was recovered.A DeKalb County grand jury indicted the defendant for malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. After a jury trial in the Superior Court of DeKalb County, the defendant was found guilty on all counts. The trial court sentenced him to life imprisonment for malice murder and a consecutive five-year term for the firearm offense, with the remaining counts merged or vacated. The defendant’s motion for new trial, and an amended motion through new counsel, were denied.The Supreme Court of Georgia reviewed the case. The court held that the trial court did not err in refusing to instruct the jury on voluntary manslaughter, as there was no evidence the defendant acted out of sudden, violent passion rather than fear or self-defense. The court also found no plain error in the prosecutor’s reference to the defendant’s invocation of his right to counsel during interrogation, as any potential error was harmless given the strong evidence of guilt. Finally, the court ruled that the defendant’s ineffective assistance claims were waived because they were not raised at the earliest practicable moment. The convictions were affirmed. View "HENDERSON v. THE STATE" on Justia Law

In this case, the defendant was charged in connection with the armed robbery and murder of an individual named Deontavious Wright. The incident occurred when three men, including the defendant, entered an apartment where Deontavious lived, along with several other people and two young children. One of the men, Rucker, held Deontavious at gunpoint, demanded drugs and money, and ultimately shot Deontavious multiple times after taking his possessions. The defendant was identified by three eyewitnesses who recognized him despite his mask, based on his clothing, physical features, and voice. Cell phone location data also placed the defendant near the scene at the relevant time. The defendant and his alibi witness testified that he was elsewhere during the crime.The Superior Court of Fulton County conducted a joint jury trial for the defendant and his co-defendants. The jury found the defendant guilty of felony murder predicated on home invasion, armed robbery, aggravated assault, cruelty to children, and firearm possession offenses, but acquitted him of malice murder and one count of aggravated assault. The court sentenced him to life imprisonment and additional terms for the other convictions. The defendant filed a motion for a new trial, which was denied, and then appealed.The Supreme Court of Georgia reviewed the case. It held that the evidence was constitutionally sufficient to support the convictions, as the jury was entitled to credit the eyewitness identifications and the corroborating cell phone evidence. The Court also found that the trial court did not err in admitting a co-defendant’s non-testimonial statements under Bruton v. United States, as those statements were not made for prosecutorial purposes. Finally, the Court held that the trial court did not abuse its discretion in denying the defendant’s motion to sever his trial from his co-defendants. The Supreme Court of Georgia affirmed the convictions. View "IVORY v. THE STATE" on Justia Law

The case concerns the fatal stabbing of Jason Cason, Jr. on November 10, 2022. Cason lived with Gary Mack, who testified that on the day of the incident, George Sharrod Johns, a friend and frequent visitor, entered Cason’s bedroom. Mack heard Cason plead, “[D]on’t hit me no more,” and soon after, saw Johns leave the apartment alone. Mack discovered Cason unresponsive and covered in blood, then saw Johns attempt to re-enter the apartment before leaving the area. Police later found bloodstains in Johns’s apartment matching Cason’s DNA. Forensic evidence established that Cason suffered 27 stab wounds, including defensive injuries, and died rapidly from chest wounds.A Fulton County grand jury indicted Johns for malice murder, felony murder, and aggravated assault. After a jury trial in December 2023, Johns was convicted on all counts. The trial court sentenced him to life in prison for malice murder, merging or vacating the other counts. Johns filed a motion for new trial, which was denied by the Superior Court of Fulton County in September 2024. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Johns’s claims that the evidence was insufficient, that the trial court erred in admitting certain autopsy photographs, and that his Confrontation Clause rights were violated by the testimony of a medical examiner who did not perform the autopsy. The court held that the evidence was constitutionally sufficient to support the conviction, the trial court did not abuse its discretion in admitting the autopsy photographs, and there was no Confrontation Clause violation because the testifying expert provided an independent opinion rather than relaying another’s findings. The court affirmed Johns’s convictions and sentence. View "JOHNS v. THE STATE" on Justia Law

Williams was convicted of malice murder and related offenses after the shooting death of his fiancée, Doninjae Jackson-Neals, in their DeKalb County apartment. The couple had a tumultuous relationship, as evidenced by text messages and testimony. On the morning of the incident, a neighbor heard sounds of a struggle from their apartment, followed by Williams fleeing the scene. Williams later called 911, claiming the shooting was accidental while demonstrating gun safety. Forensic evidence showed the gun was pressed against the victim’s head when fired, contradicting Williams’s account. Williams was arrested at the scene and gave a statement to police.After a mistrial in his first proceeding, Williams was retried in the Superior Court of DeKalb County and found guilty on all counts. He was sentenced to life imprisonment with the possibility of parole for malice murder, plus additional terms for aggravated assault and firearm possession. Williams filed a motion for new trial, which was amended by new counsel. The trial court denied the motion on substantive grounds but granted it as to the merger of aggravated assault into malice murder, indicating a need for resentencing on that issue. Williams then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Williams’s claims of ineffective assistance of counsel. The Court held that Williams failed to preserve for review his claims regarding his counsel’s failure to object to certain testimony and related comments during closing argument. As to his remaining claims about the State’s opening statement, the Court found no prejudice, given the trial court’s instructions and the strength of the evidence against Williams. The Court affirmed the judgment, leaving open the possibility of resentencing to correct the merger error. View "WILLIAMS v. THE STATE" on Justia Law

The case concerns a defendant who, after leading police on a high-speed chase that resulted in a fatal crash killing his passenger, was charged with multiple offenses, including felony murder and vehicular homicide. On the day his trial was set to begin, the defendant agreed to plead guilty to certain charges in exchange for the State withdrawing its notice seeking a recidivist sentence of life without parole and dismissing several other counts. During the plea colloquy, the defendant confirmed under oath that he understood the proceedings, his rights, and the consequences of his plea, despite having a history of seizures and reportedly experiencing a seizure about an hour before the plea.After sentencing, the defendant, represented by new counsel, moved to withdraw his guilty plea, arguing that it was not knowing or voluntary due to the seizure he allegedly suffered before the plea. At the hearing on the motion, his former counsel testified that she observed an incident consistent with a seizure but took steps to ensure the defendant was oriented and understood the proceedings before proceeding. The defendant testified that he did not recall the plea or the seizure but acknowledged answering questions during the colloquy. The Superior Court of the relevant county denied the motion, finding the defendant’s testimony not credible and crediting plea counsel’s account and the plea transcript.The Supreme Court of Georgia reviewed the case and affirmed the trial court’s denial of the motion to withdraw the guilty plea, holding that the record supported the conclusion that the plea was knowing and voluntary. The Court also sua sponte vacated the sentence for vehicular homicide, as it merged by law with the felony murder conviction involving the same victim. The judgment was thus affirmed in part and vacated in part. View "ROBINSON v. THE STATE" on Justia Law

Addonis Rhodes was convicted of malice murder and other offenses related to the shooting death of Vernard Mays. The incident occurred when Rhodes, along with several co-indictees who were members of the “10-12” street gang and the Crips, went to Mays’s mother’s home searching for a missing gun. Believing someone in the house had taken the gun, Rhodes and his associates confronted Mays at the back door. After a brief exchange, Rhodes, prompted by a signal from another co-indictee, shot Mays, and others also fired. Mays died from a gunshot wound to his leg. In the days following the shooting, Rhodes attempted to kill a co-indictee, Curtis Jackson, Jr., whom he suspected of implicating him in the crime.A Bibb County grand jury indicted Rhodes and four others for malice murder, felony murder, and violation of the Street Gang Terrorism and Prevention Act. Three co-indictees pleaded guilty and testified against Rhodes and Jackson, who were tried together. The Superior Court of Bibb County jury found both guilty on all charges. Rhodes was sentenced to life in prison for malice murder, with other counts vacated. After his conviction, Rhodes filed a motion for new trial, which was denied.On appeal to the Supreme Court of Georgia, Rhodes argued that the trial court erred in admitting a Facebook post he made shortly after the murder and that his trial counsel was ineffective in several respects. The Supreme Court of Georgia held that the Facebook post was relevant and its probative value was not substantially outweighed by unfair prejudice. The court also found that Rhodes failed to show his counsel was ineffective for not moving to exclude gang evidence, not seeking a bifurcated trial, not moving to exclude evidence of his plot against Jackson, or failing to convey a plea offer. The court affirmed the judgment. View "RHODES v. THE STATE" on Justia Law

Two men, Ratliff and Calvert, traveled from Mississippi to Dublin, Georgia, to retrieve a firearm. Upon arrival at a ballpark, they met with a man in a red car, and shortly after, a black car arrived with several masked men. The group, including the man from the red car, brandished weapons, forcibly removed Calvert from the vehicle, and pistol-whipped him. During the chaos, Ratliff attempted to flee but was fatally shot in the back with a Draco-style gun. The assailants stole Calvert’s phone and fled. Later, Jeremiah Fripp and another man, Salter, went to a police station in South Carolina, where Fripp admitted to the shooting. A search of Fripp’s car revealed the murder weapon, which was traced back to Ratliff as the original purchaser.A Laurens County grand jury indicted Fripp on multiple charges, including malice murder, felony murder, armed robbery, aggravated assault, and possession of a firearm during the commission of a felony. After a jury trial, Fripp was convicted on all counts. The Superior Court of Laurens County sentenced him to life without parole for malice murder, with additional consecutive sentences for armed robbery and firearm possession. Fripp’s motions for a new trial were denied.On appeal, the Supreme Court of Georgia reviewed Fripp’s claims that the evidence was insufficient, his counsel was ineffective for not pursuing an alibi defense, and the trial court erred in its jury instruction on coercion. The Court held that the evidence, including Fripp’s admissions and physical evidence, was sufficient for conviction. It found no prejudice from counsel’s failure to call alibi witnesses, as none were identified or presented. The Court also determined that any error in the coercion instruction was harmless given the strength of the evidence and the overall jury instructions. The judgment was affirmed. View "FRIPP v. THE STATE" on Justia Law

The case concerns Kenneth Robinson, who was convicted of malice murder and other offenses related to the shooting death of Devontae Jones and the aggravated assault of Charmisa Witherspoon. The evidence showed that Robinson, age fourteen at the time, was involved with the 9 Trey Bloods gang. After a gang member, Jesus Cintron, disappeared, the gang’s leader plotted to kill Witherspoon and her son, fearing Witherspoon would cooperate with law enforcement. Robinson and other gang members went to Witherspoon’s house, where Robinson participated in the assault. Witherspoon escaped, but her son was killed. Robinson was tried alongside several co-defendants.The Superior Court of Fulton County granted Robinson a directed verdict on several counts and dead docketed one count, later nol prossed. The jury found Robinson guilty on the remaining counts except one. He was sentenced to life plus forty-five consecutive years. Robinson filed a motion for new trial, which was denied. His initial appeal was dismissed due to a pending count, but after that count was nol prossed, he filed an amended notice of appeal.The Supreme Court of Georgia reviewed the case. Robinson argued that his trial counsel was ineffective for failing to communicate a plea offer, that his sentencing procedure violated constitutional and statutory rights, that the trial court misunderstood its sentencing discretion, and that certain counts should have merged for sentencing. The court held that trial counsel did communicate the plea offer, so there was no deficient performance. The court also found no constitutional or statutory violation in the sentencing procedure, noting that neither Robinson nor his counsel objected or requested to be heard. Claims regarding the trial court’s sentencing discretion and merger of counts were found to be waived or without merit. The Supreme Court of Georgia affirmed Robinson’s convictions. View "ROBINSON v. THE STATE" on Justia Law

On July 30, 2008, Barry Bullard was shot and killed in Tift County, Georgia. The incident followed a series of disputes between Bullard and three men: Jeremy Reynolds, Neddrick Green, and Allen Williams. Tensions had escalated after Williams believed Bullard had stolen a gun from him, leading to repeated confrontations. On the night of the shooting, witnesses observed Williams, Green, and Reynolds driving by Bullard’s home, after which a confrontation ensued in Bullard’s yard. Testimony at trial indicated that after a brief altercation, Reynolds approached Bullard and shot him in the head at close range. Multiple eyewitnesses identified Reynolds as the shooter, and physical evidence, including fingerprints and a recovered firearm, further linked him to the crime.Following the incident, a Tift County grand jury indicted Reynolds, Green, and Williams for malice murder, with Reynolds also facing a charge of possession of cocaine. Williams was tried separately and convicted, while Reynolds and Green were jointly tried and found guilty by a jury in November 2010. Reynolds was sentenced to life in prison without parole for malice murder and received a concurrent 30-year sentence for possession of cocaine. After his conviction, Reynolds filed a motion for a new trial, which was amended and ultimately denied by the trial court in August 2023.The Supreme Court of Georgia reviewed Reynolds’s appeal, in which he argued that the evidence was constitutionally insufficient to support his malice murder conviction. The Court applied the standard from Jackson v. Virginia, considering whether a rational trier of fact could have found Reynolds guilty beyond a reasonable doubt. The Court held that the evidence, including eyewitness testimony and corroborating physical evidence, was sufficient to sustain the conviction. The judgment of the trial court was affirmed. View "REYNOLDS v. THE STATE" on Justia Law

The case concerns a woman who was convicted of felony murder and other offenses after fatally shooting her husband during a domestic dispute. The incident occurred after an argument about alleged infidelity, with both parties having a history of mutual violence. On the day of the shooting, the woman and her son waited in a car while her husband prepared to confront the alleged third party. After a delay, she re-entered the house, an argument ensued, and she shot her husband, who later died. The woman claimed the shooting was accidental or in self-defense, citing a history of abuse and presenting expert testimony on battered person syndrome. The prosecution, however, presented evidence that contradicted her account, including testimony that she had loaded the gun earlier and that she had previously threatened or been violent toward her husband.The Superior Court of Jackson County held a jury trial, where the woman was acquitted of malice murder but convicted of felony murder, aggravated assault, cruelty to children in the second degree, and firearm offenses. She was sentenced to life in prison and other concurrent and consecutive terms. After her conviction, she filed a motion for a new trial, arguing that the verdict was against the weight of the evidence and that the court failed to properly consider her battered person syndrome defense and her motion for immunity. The trial court denied her motion.The Supreme Court of Georgia reviewed the case and affirmed the convictions. The Court held that the evidence was constitutionally sufficient to support the verdicts, as the jury was entitled to disbelieve the defendant’s claims of accident or self-defense. The Court also found that the trial court properly exercised its discretion in denying a new trial and correctly determined that the defendant had not established entitlement to immunity by a preponderance of the evidence. View "WHISNANT v. THE STATE" on Justia Law