Justia Criminal Law Opinion Summaries

The case concerns an individual who was indicted for multiple offenses, including malice murder, felony murder predicated on aggravated assault, and related firearm charges, following the shooting death of a man in Clayton County, Georgia. The incident occurred after a confrontation in a motel parking lot, where witnesses reported that the defendant instructed a co-indictee to shoot the victim, resulting in the victim’s death nearly a year later from complications related to the gunshot wounds. The defendant initially pleaded not guilty but later entered a negotiated guilty plea to felony murder.The Superior Court of Clayton County accepted the guilty plea after a hearing in which the defendant completed a detailed waiver form and participated in a colloquy with the judge to confirm his understanding of his rights, including the right to withdraw his plea before sentencing. The court merged certain charges for sentencing, vacated others by operation of law, and sentenced the defendant to life in prison with the possibility of parole. The defendant did not attempt to withdraw his plea before or after sentencing but appealed, arguing that the trial court erred by accepting his plea without a sufficient factual basis and by requiring him to waive his right to withdraw the plea prior to sentencing.The Supreme Court of Georgia reviewed the appeal and held that the trial court satisfied the requirement to establish a factual basis for the plea, as the prosecutor’s proffered facts were sufficient to support the felony murder charge. The Court further held that the statutory right to withdraw a guilty plea before sentencing is waivable if the waiver is made knowingly, voluntarily, and intelligently, and found that the record demonstrated a valid waiver in this case. The Supreme Court of Georgia affirmed the conviction and sentence. View "PRIEST v. THE STATE" on Justia Law

The case concerns the conviction of a man for the malice murder of his wife, who was found beaten and stabbed to death in their Georgia home. The victim’s mother and son, after being unable to reach her, traveled from Chicago to Georgia and, with police assistance, eventually discovered her body concealed under a pile of clothes. The investigation revealed a history of controlling and violent behavior by the defendant toward the victim, evidence of his flight from Georgia to Chicago in the victim’s car, and his subsequent armed standoff with police in Chicago, during which he threatened suicide and possessed knives matching those found at the crime scene.A Henry County grand jury indicted the defendant for malice murder, felony murder, and aggravated assault. After a jury trial in the Superior Court of Henry County, he was found guilty on all counts and sentenced to life without parole. The defendant filed a motion for new trial, which was denied after an evidentiary hearing. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia affirmed the convictions and sentence. The court held that trial counsel was not constitutionally ineffective for failing to request a specific jury instruction on impeachment by bias, as the instructions given sufficiently covered the concept. The court also found no plain error in the admission of certain forensic testimony and reports, concluding that any potential Confrontation Clause violation did not affect the outcome given the overwhelming evidence of guilt. The admission of evidence regarding knives found in the defendant’s possession was deemed intrinsic to the case and not unfairly prejudicial. Finally, the court rejected the claim of cumulative error, finding no denial of a fundamentally fair trial. View "FELTON v. THE STATE" on Justia Law

Two individuals, India Royal and Cameron Woods, were found shot to death in their car in a Walmart parking lot in Riverdale, Georgia, on January 13, 2017. The investigation revealed that both victims were killed by 9mm bullets while seated in their vehicle, which contained evidence of drug distribution. Surveillance footage showed a distinctive white Mercury Mountaineer circling the parking lot before the shooting, and a tall man was seen exiting the Mountaineer, entering the victims’ car, and then leaving shortly before the Mountaineer drove away. The vehicle was registered to the appellant’s mother, who confirmed that her son, Deanthony Ealey, had possession of it that day. Cell phone records linked communications between Woods and a number associated with Ealey around the time of the murders. Ealey was later identified as the person driving the Mountaineer at a nearby ATM after the murders.The Superior Court of Clayton County tried Ealey on two counts of malice murder, two counts of felony murder, and two counts of aggravated assault. The jury found him guilty on all counts, and he was sentenced to consecutive life terms without parole. Ealey filed a motion for a new trial, which was denied after evidentiary hearings.The Supreme Court of Georgia reviewed Ealey’s appeal, in which he argued that the evidence was insufficient, that the trial court erred in admitting other-acts and hearsay evidence, that his counsel was ineffective, and that cumulative errors warranted reversal. The court held that the evidence was sufficient to support the convictions under both constitutional and Georgia statutory standards, that any errors in admitting other-acts or hearsay evidence were harmless, and that Ealey failed to show ineffective assistance or cumulative error. The Supreme Court of Georgia affirmed Ealey’s convictions and sentences. View "EALEY v. THE STATE" on Justia Law

On August 29, 2019, the appellant was involved in a fatal shooting at a hotel in Gwinnett County, Georgia. The incident arose from a planned drug transaction involving methamphetamine, in which the appellant, along with two co-defendants, participated. The victim, who was a friend of one co-defendant, was shot and killed during the attempted drug deal. The appellant was later arrested, and his statements to police, as well as his trial testimony, indicated his involvement in the conspiracy to possess methamphetamine with intent to distribute. Surveillance footage, witness testimony, and physical evidence corroborated the sequence of events leading to the shooting.A Gwinnett County grand jury indicted the appellant and others on multiple charges, including felony murder predicated on conspiracy to possess methamphetamine with intent to distribute. At trial in the Superior Court of Gwinnett County, the jury found the appellant guilty of felony murder based on the drug conspiracy, conspiracy to violate the Georgia Controlled Substances Act, and possession of a firearm during the commission of a crime. He was acquitted of other charges. The trial court sentenced him to life without parole plus a consecutive five-year term. After his motion for a new trial was denied, the appellant appealed.The Supreme Court of Georgia reviewed the case, focusing on whether the evidence was constitutionally sufficient to support the felony murder conviction predicated on the drug conspiracy. The Court held that the evidence, viewed in the light most favorable to the verdict, was sufficient for a rational jury to find the appellant guilty beyond a reasonable doubt. The Court concluded that a conspiracy to possess methamphetamine with intent to distribute is inherently dangerous and that the victim’s death was a reasonably foreseeable consequence of the conspiracy. The judgment was affirmed. View "PINION-LOPEZ v. THE STATE" on Justia Law

The case concerns an incident in which Roy Blane Dees attacked Jimmy Vance with a hammer in Vance’s front yard, resulting in Vance’s death a few days later. Several neighbors either witnessed or heard the attack and later identified Dees as the assailant. After the assault, Dees left the scene and was eventually apprehended at a nearby gas station. The evidence at trial included eyewitness testimony, a 9-1-1 call, and police body camera footage capturing witness statements at the scene.A Rockdale County grand jury indicted Dees on multiple charges, including malice murder, felony murder, aggravated assault, and aggravated battery. At trial in the Superior Court of Rockdale County, the jury found Dees guilty of felony murder predicated on aggravated assault and aggravated assault, but acquitted him of the other charges. The court sentenced Dees to life in prison without parole. Dees filed a motion for a new trial, which was denied, and then appealed his convictions.The Supreme Court of Georgia reviewed Dees’s claim that the trial court erred by admitting police officers’ testimony recounting what witnesses told them at the scene, arguing this was inadmissible hearsay. Because Dees did not object at trial, the Court applied the plain error standard. The Court held that, under Georgia law, hearsay evidence is admissible if not properly objected to, and no controlling authority required the trial court to exclude such evidence sua sponte. Therefore, the trial court did not commit plain error, and the Supreme Court of Georgia affirmed Dees’s convictions. View "DEES v. THE STATE" on Justia Law

Edward Morris was convicted by a jury of murder, aggravated assault, criminal street gang activity, and related offenses stemming from two incidents involving victims Randy Griffin and Lacey Magee. Morris was a member of a group known as the International Robbing Club (IRC), which planned and executed robberies. In May 2007, IRC members attempted to rob Griffin, resulting in Magee being shot and Griffin returning fire. Later, in June 2007, Griffin was shot and killed outside a nightclub, with evidence including accomplice testimony, cell tower records, and statements from Morris’s former girlfriend placing Morris at the scene and implicating him in the planning and execution of the crime.After his conviction, Morris’s trial counsel withdrew a motion for new trial and filed an appeal. The Supreme Court of Georgia affirmed Morris’s convictions, finding the evidence sufficient. Morris later filed a habeas corpus petition, alleging ineffective assistance of both trial and appellate counsel on several grounds, including failure to ensure his presence at bench conferences, failure to consult or call a cell tower expert, failure to interview or call a co-indictee as a witness, and withdrawal of the motion for new trial without his consent. The habeas court granted relief on all but one claim.The Supreme Court of Georgia reviewed the habeas court’s decision and reversed the grant of relief on all grounds except one, which was remanded for further consideration. The Court held that Morris’s claims of ineffective assistance of trial counsel were procedurally defaulted and that he failed to show appellate counsel was ineffective for not raising those claims. The Court also found that appellate counsel was not ineffective for failing to raise other direct claims. The disposition was reversed in part and remanded in part. View "SPRAYBERRY v. MORRIS" on Justia Law

The case concerns a man who was convicted of malice murder and related offenses following the death of his girlfriend. The two had a tumultuous relationship, and on the day in question, the victim was last heard from after telling her cousin she planned to leave the defendant. The next day, the defendant’s brother discovered the couple’s home on fire, and the victim was found dead inside. Investigators determined the fire was intentionally set and that the victim had died from neck compression before the fire started. The defendant gave conflicting accounts to law enforcement, ultimately admitting to setting the fire to cover up the death and to strangling the victim, though he claimed it was not intentional and that she had pointed a gun at him.A Warren County jury found the defendant guilty on all counts, including malice murder, arson, and concealing a death. The trial court sentenced him to life without parole for malice murder, with additional terms for arson and concealing a death. The felony murder conviction was vacated by operation of law, and the aggravated assault count was merged with the vacated felony murder count. The defendant’s motion for a new trial was denied by the Superior Court of Warren County.On appeal, the Supreme Court of Georgia reviewed the sufficiency of the evidence and the trial court’s handling of the motion for new trial. The Court held that the evidence included direct admissions by the defendant and was not solely circumstantial, so the statutory standard for circumstantial evidence did not apply. The Court also found that the trial court properly exercised its discretion as the “thirteenth juror” in denying a new trial. The Supreme Court of Georgia affirmed the convictions. View "TUCKER v. THE STATE" on Justia Law

Yvette Renee Garcia was charged with assault with a deadly weapon and two counts related to driving under the influence of alcohol, following an incident in which she, while intoxicated, deliberately rammed her car into another vehicle during an argument. A breath test showed her blood-alcohol concentration was between .22 and .24. The charges stemmed from a single course of conduct.The Superior Court of Los Angeles County denied Garcia’s request for mental health diversion under Penal Code section 1001.36, finding her ineligible due to the DUI charges. Garcia then pleaded no contest to the assault and one DUI count, while the other DUI count was dismissed. The court imposed three years of formal probation for both the assault and DUI convictions, with additional conditions including community labor and jail time already served. Garcia appealed, and the trial court issued a certificate of probable cause.The California Court of Appeal, Second Appellate District, Division One, reviewed the case. The court held that Vehicle Code section 23640 bars diversion in any case where a defendant is charged with a DUI offense, regardless of whether other non-DUI charges are included in the same case. The court rejected Garcia’s argument that she should be eligible for diversion on the assault charge, since all charges arose from a single incident and were prosecuted together. The court also found that the probation term for the assault charge exceeded the statutory maximum and modified it from three years to two years, while affirming the judgment as modified. The trial court was directed to amend the abstract of judgment accordingly. View "People v. Garcia" on Justia Law

Carlos Mendoza was charged with second degree robbery and assault with force likely to cause great bodily injury, along with related enhancements, following an incident in San Francisco. At his arraignment on the original felony complaint, Mendoza pled not guilty and waived his right to a preliminary hearing within 10 court days, but did not waive his right to a preliminary hearing within 60 days. Shortly before the expiration of the 60-day period, the prosecution moved to amend the complaint to add gang-related allegations and a new count for participation in a criminal street gang, based on recent discovery. Mendoza was arraigned and pled not guilty to the amended complaint, but did not waive the 60-day time limit.The Superior Court of the City and County of San Francisco permitted the amendment and recalculated the statutory time limits, treating the arraignment on the amended complaint as restarting the 60-day period for holding a preliminary hearing. Mendoza’s counsel objected, arguing the preliminary hearing should occur within 60 days of the original arraignment. The trial court denied motions to dismiss based on violation of the 60-day limit, holding that material amendments to the complaint could restart the statutory period unless prompted by improper purpose. After the preliminary hearing, Mendoza was held to answer, and subsequent motions to dismiss were denied.The California Court of Appeal, First Appellate District, Division Three, reviewed Mendoza’s petition for writ of mandate or prohibition. Although the underlying criminal case was dismissed as moot, the appellate court exercised its discretion to resolve the legal question. The court held that, absent a personal waiver by the defendant, an arraignment or plea on an amended complaint does not restart the 60-day period for holding a preliminary hearing under Penal Code section 859b. The statutory 60-day limit is absolute, and its purpose is to protect a defendant’s right to a speedy preliminary hearing. The petition was dismissed as moot. View "Mendoza v. Superior Court" on Justia Law

A man was shot and killed outside a convenience store in Wilmington, Delaware. Surveillance footage captured the masked shooter’s movements before and after the incident, and police identified several witnesses, including Darnella Spady, who was present at the scene. During a police interview, Spady identified the shooter as “Gunner,” later determined to be Kevin Berry, and described her interactions with him. However, at trial, Spady was uncooperative, claimed memory loss due to drug use, and stated she could not recall the shooting or her prior statement to police. The prosecution sought to admit Spady’s out-of-court statement as substantive evidence under 11 Del. C. § 3507.The Superior Court of the State of Delaware conducted a bench trial after Berry waived his right to a jury. The court admitted Spady’s prior statement over Berry’s objection, finding that the State had established the necessary foundation under Section 3507 and that the statement was voluntary. The court found Berry guilty of first-degree murder and related weapons charges, and sentenced him to life plus ten years. Berry appealed, arguing that the trial court erred in admitting Spady’s statement and urging the Delaware Supreme Court to overturn its recent precedent in McCrary v. State, which clarified the foundational requirements for admitting such statements.The Supreme Court of the State of Delaware reviewed the case and affirmed the Superior Court’s decision. The Court held that there was no urgent reason or clear error warranting a departure from McCrary v. State, and that the trial court did not abuse its discretion in admitting Spady’s statement. The Court concluded that the State’s questioning satisfied the statutory requirements, and Berry’s confrontation rights were not violated. The convictions were affirmed. View "Berry v. State" on Justia Law