Justia Criminal Law Opinion Summaries

Austin McIntyre was convicted of felony murder and conspiracy to commit armed robbery in connection with the shooting death of Willie Thomas. Appellant claimed on appeal: (1) the evidence presented at his trial was insufficient to support his convictions; (2) the trial court erred by failing to charge the jury on voluntary manslaughter; and (3) that he was denied constitutionally effective assistance of counsel. Finding no reversible error, the Georgia Supreme Court affirmed Appellant's convictions. View "McIntyre v. Georgia" on Justia Law

Daniel Anglin appealed his convictions for malice murder and other crimes in connection with the 2016 shooting death of Chad Ruark. Anglin argued the trial evidence was insufficient to support his convictions; the trial court erred in handling an untimely disclosure that someone else purportedly confessed to killing Ruark; trial counsel was ineffective for failing to object to a lay witness’ scientific conclusions; and the cumulative effect of these errors prejudiced him. The Georgia Supreme Court affirmed, finding the evidence was sufficient to authorize a jury to conclude that Anglin was guilty; Anglin did not show the untimely disclosure prejudiced him; trial counsel was not ineffective for failing to object to the witness’s testimony because it was not based on scientific training or other specialized knowledge; and there were no errors to consider cumulatively. View "Anglin v. Georgia" on Justia Law

Nashea Poole was convicted by jury of felony murder and related offenses in connection with crimes committed against Jordan and Chad Collins. The Collins brothers were at their sister's home where they were visited by Clarissa McGhee and Poole, whom Jordan had met through the “Plenty of Fish” dating website. After approximately an hour, Jordan decided to take the women to his house and prepared to leave. Shortly thereafter, Chad heard the back screen door slam, followed by a commotion. Chad then heard a gunshot and ran outside, where he saw Jordan lying on the patio. Chad was then shot several times. He made his way to the garage, where he found McGhee. Chad yelled at McGhee and began chasing McGhee, who pulled out a gun, pointed it at Chad, and then fled. Chad survived, but Jordan died of his wounds. McGhee, who pled guilty to aggravated assault, testified for the State, implicating Poole as a gang member, and for participating in the plot to "lure 'johns' under the pretense of prostitution services, for the purpose of robbing [the victim]." Poole raised numerous claims alleging that the evidence presented at trial was insufficient to support her convictions. Finding no reversible error, the Georgia Supreme Court affirmed. View "Poole v. Georgia" on Justia Law

Appellant Raphael Johnson was convicted of the 2013 malice murder of Frederick Burke, the 2013 felony murder of James Cornelius, and other crimes in connection with a shooting incident at a “gambling house,” and the aggravated battery of Ahmed Rayner in connection with another shooting at a restaurant a week later. In his appeal to the Georgia Supreme Court, Appellant contended: (1) the evidence presented at his trial was legally insufficient to support his convictions for the aggravated battery of Rayner; (2) that the trial court’s jury instruction on aggravated assault constituted plain error; and (3) that the trial court abused its discretion by concluding that evidence of another shooting incident that occurred a few hours before the gambling house shootings was admissible as intrinsic evidence. The Supreme Court rejected these contentions and affirmed Appellant’s convictions, except for his conviction for possession of a firearm during the commission of a felony, which was vacated to correct a merger error. View "Johnson v. Georgia" on Justia Law

Brantley Washington and his co-defendants, Chrishon Siders and Haleem Graham, were convicted of malice murder, first degree burglary, and other crimes in connection with the 2016 shooting death of Seine Jackson. Washington appealed, arguing the trial court erred in admitting hotel surveillance videos from the day before and the day of the crimes, along with the opinion testimony of two detectives describing the surveillance videos and a dashcam video recording of a traffic stop taken on the night of the crimes. Washington also claimed he received ineffective assistance of counsel when his trial counsel failed to object to that evidence. Finding no reversible error, the Georgia Supreme Court affirmed Washington's convictions. View "Washington v. Georgia" on Justia Law

A jury found Mustafa Mahdi guilty but mentally ill of the 2014 malice murder of John Quincy III and guilty of possession of a knife during the commission of a felony. Appealing pro se appeal, Mahdi broadly claimed the trial court, as well as his trial and appellate counsel, violated his constitutional rights. After review, the Georgia Supreme Court discerned from these claims that Mahdi was arguing: (1) the trial court violated his due process rights by allowing his trial attorneys to present an insanity defense against his wishes; (2) he received ineffective assistance of trial and motion-for-new trial counsel; and (3) his trial and motion counsel violated his right to conflict-free representation. Finding no reversible error, the Supreme Court affirmed Mahdi's convictions. View "Mahdi v. Georgia" on Justia Law

Darius Dunn appealed his convictions for malice murder and other charges in connection with the 2015 shooting death of Anthony Tavarez. Dunn claimed on appeal that the evidence at trial was insufficient to support his conviction for a violation of the Georgia Street Gang Terrorism and Prevention Act. He also argued the trial court abused its discretion in admitting alleged bad character evidence and allegedly irrelevant and prejudicial video evidence. Finally, Dunn contended he received constitutionally ineffective assistance of counsel because his trial counsel did not seek to redact the State’s exhibits to exclude allegedly irrelevant and prejudicial bad character evidence. Finding no reversible error, the Georgia Supreme Court affirmed. View "Dunn v. Georgia" on Justia Law

Tonya Tidwell was convicted by jury of malice murder and aggravated battery in connection with the death of David Guice. On appeal, Tidwell claimed the trial court erred by failing to charge the jury on mutual combat and by failing to suppress evidence obtained during the post-incident search of the crime scene. Finding no reversible error, the Georgia Supreme Court affirmed Tidwell's conviction. View "Tidwell v. Georgia" on Justia Law

Appellant Gerrod Crawford was convicted of felony murder and other crimes related to the 2015 shooting death of Antonio McBride. On appeal, he contended the trial court should have granted his motion for a directed verdict of acquittal and that his trial counsel provided ineffective assistance by failing to make a timely objection to an improper statement made by the prosecutor during her closing argument. Finding no reversible error, the Georgia Supreme Court affirmed. View "Crawford v. Georgia" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion to suppress his federal New Hampshire prosecution on double jeopardy grounds, holding that Defendant's double jeopardy rights did not attach in earlier Maine criminal proceedings.In 2018, Defendant was indicted in the District of Maine with criminal offenses. On January 31, 2020, the United States filed a motion to dismiss the indictment without prejudice. Defendant filed a motion for a judgment of acquittal or dismissal with prejudice, arguing that, given the government's accompanying admission that it could not prove its case and his lengthy pretrial detention, due process required an acquittal or dismissal with prejudice. The district court denied the motion and dismissed the case without prejudice. Also on January 31, 2020, the United States filed a criminal complaint in the New Hampshire district court. A grand jury issued an indictment. Defendant moved to dismiss count two on double jeopardy grounds. The district court denied the motion. The First Circuit affirmed, holding that jeopardy did not attach to Defendant's Maine criminal proceedings. View "United States v. Suazo" on Justia Law