Justia Constitutional Law Opinion Summaries

The Ninth Circuit reversed the district court's denial of a habeas corpus petition challenging petitioner's first-degree murder conviction and remanded with instructions to conditionally grant the writ. In this case, the prosecutor told the jury at the end of his closing-argument rebuttal that the presumption of innocence no longer applied.The panel applied petitioner's claim pursuant to Darden v. Wainwright, 477 U.S. 168 (1986), de novo, holding that the prosecutor's repeated statements, endorsed by the trial judge, that the presumption of innocence no longer applied violated due process under Darden. The panel stated that a holding of a due process violation under Darden necessarily entails a conclusion that the prosecutor's misstatements of the law were prejudicial. The panel also held that the Court of Appeal unreasonably concluded under Chapman v. California, 386 U.S. 18 (1967), that the prosecutor’s misstatements of the law were harmless beyond a reasonable doubt. View "Ford v. Peery" on Justia Law

Andre Bridgewater was tried by jury and convicted of murder and other crimes in connection with the fatal shooting of Myron Short. Bridgewater appealed, contending that the evidence was insufficient to sustain his convictions and that the trial court erred when it admitted the prior inconsistent statements of a witness. Finding no error, the Georgia Supreme Court affirmed. View "Bridgewater v. Georgia" on Justia Law

James Eggleston was tried by jury and convicted of felony murder and possession of a firearm during the commission of a felony in connection with Richard Byrd’s death. Following the denial of his motion for new trial, Eggleston appealed, contending only that the evidence presented at trial was insufficient to sustain his convictions. Because the evidence was sufficient, the Georgia Supreme Court affirmed. View "Eggleston v. Georgia" on Justia Law

Donald Griffin was convicted by jury of felony murder in connection with the stabbing death of Truitt Cheeley. Griffin appealed the denial of his motion for a new trial, contending that the trial court erred in admitting into evidence witness testimony about Griffin’s racism and Griffin’s custodial statement. Griffin also claimed his trial counsel was constitutionally ineffective. Furthermore, Griffin contended the trial court erred in denying his request to cross-examine a witness who testified as to Cheeley’s reputation for peacefulness with evidence that Cheeley had been convicted of a crime of violence. Finding no reversible error, the Georgia Supreme Court affirmed. View "Griffin v. Georgia" on Justia Law

Todd Welch was convicted by jury of murder and other crimes in connection with the shooting death of Christopher Brown and the aggravated assault of Darrell Agee. Welch contended on appeal that the trial court erred by improperly admitting hearsay evidence under the forfeiture-by-wrongdoing exception to the rule against hearsay, and erred by failing to give his requested jury instruction on grave suspicion. After review, the Georgia Supreme Court concluded the arguments Welch raised were without merit. However, the Court found it had to vacate Welch’s sentences as to Counts 10 and 20 of his indictment in order to correct sentencing errors that harmed him. View "Welch v. Georgia" on Justia Law

Patrick Satterfield was convicted by jury of felony murder and other crimes in connection with the death of Richard Boynton. On appeal, Satterfield contended the evidence was insufficient to support the verdicts and that his trial counsel was ineffective. Finding no reversible error, the Georgia Supreme Court affirmed his convictions. View "Satterfield v. Georgia" on Justia Law

Appellant Darien Meheux appealed his 2014 conviction for the malice murder of Jasmine Benjamin, claiming the trial court erred in admitting a handwritten statement and that his trial counsel was constitutionally ineffective. Because Meheux, acting pro se, filed a motion for new trial while he was still represented by trial counsel and his amended motion for new trial filed by counsel was untimely, the Georgia Supreme Court determined the trial court should have dismissed the motion rather than deciding it on the merits, and therefore vacated the judgment and remanded the case with direction to the trial court to dismiss the motion. View "Meheux v. Georgia" on Justia Law

Appellant Roshun Gray was convicted of malice murder and two firearm offenses in connection with the 2012 shooting death of Ferderian Bennett. On appeal, Appellant contended he was legally incompetent to stand trial and that his trial counsel provided ineffective assistance by failing to investigate his incompetency. Finding both of those claims as meritless, the Georgia Supreme Court affirmed. View "Gray v. Georgia" on Justia Law

Otis Hill shot Christina and Marshall Wellington when they were unable to pay a drug debt. Christina died; Marshall survived but lost an eye. Hill and Aviance Marshall, who drove Hill and the Wellingtons to the location of the shooting, were charged with malice murder, attempted murder, kidnapping, and related offenses. Hill was convicted of kidnapping and murdering Christina, kidnapping, battering, and attempting to murder Marshall, and a weapons charge. On appeal, Hill argued the evidence was insufficient as to kidnapping. In addition, Hill contended the trial court erred: in using a deficient master jury list; in failing to determine whether a juror was proficient in English; in instructing the jury regarding note taking; in admitting evidence of cell site location information, the effects of cocaine on memory, and witness intimidation; in excluding evidence of the maximum penalty Aviance faced; in instructing the jury regarding the reasonable-doubt standard; and in denying his motion for a new trial on the general grounds. Hill also claimed he received ineffective assistance of counsel. The Georgia Supreme Court found none of Hill's enumerations of error and affirmed, but vacated in part to correct sentencing errors. View "Hill v. Georgia" on Justia Law

Antavian Love was convicted of malice murder and other crimes in connection with the shooting death of Enrique Trejo. On appeal, Love, who was 16 years old at the time the crimes were committed, argued the trial court erred in denying the motion to suppress his statements to law enforcement and in sentencing him as a juvenile to serve life without parole. Finding no reversible error, the Georgia Supreme Court affirmed his convictions. View "Love v. Georgia" on Justia Law