Justia Constitutional Law Opinion Summaries

Following a jury trial, Mary Ann Bragg was found guilty of malice murder, felony murder, and aggravated assault in connection with the murder of her husband, Tom. On appeal, Bragg argued, among other things, that the trial court erred by admitting similar transaction evidence of soliciting others to kill her husband, and by improperly charging the jury on parties to a crime. Bragg further claimed that trial counsel rendered ineffective assistance. Finding no reversible error, the Supreme Court affirmed. View "Bragg v. Georgia" on Justia Law

Appellant Louise Shorter Barzey challenged the constitutionality of certain provisions in the Workers' Compensation Act that precluded her, as a non-dependent parent, from recovering benefits for the death of her son, Deron Shorter, from his employer, the City of Cuthbert. Shorter was killed in 2010 while acting in the course of his employment with the City. He was 37 at the time of his death, was not married, and had no dependents. His mother Barzey was his only heir at law. After Shorter's death, Barzey filed a lawsuit against the City, seeking a judgment declaring that she has the right to sue the City. Barzey acknowledged that the Workers' Compensation Act provided the exclusive remedy of an employee's heirs for the employee's death during the course of his employment. She also acknowledged that the Act expressly said that the compensation for a deceased employee "shall be payable only to dependents and only during dependency." After its review, the Supreme Court affirmed the trial court’s ruling that the Act's limitation on the recovery of nondependent heirs did not violate Barzey's constitutional rights to due process and equal protection. View "Barzey v. City of Cuthbert" on Justia Law

This appeal stemmed from complaints filed by appellants Advanced Disposal Services Middle Georgia, LLC and Lowndes County, seeking injunctions prohibiting appellee Deep South Sanitation, LLC from providing solid waste collection and disposal services in the unincorporated areas of Lowndes County in violation of a newly enacted Lowndes County ordinance. The trial court denied appellants' requests for injunctive relief, and they appealed. The trial court determined that injunctive relief could not be granted in favor of appellants because enforcement of the Ordinance would violate Deep South's due process rights by interfering with its right to conduct business in the same manner as before enactment of the Ordinance. Because Deep South's substantive due process defense involved neither a suspect class nor a fundamental right, the Supreme Court applied a rational relationship test to determine whether enforcement of the Ordinance against Deep South would violate due process. Applying this test, the Court concluded the trial court erred by holding that enforcement of the Ordinance against Deep South would violate its due process rights. Furthermore, the Court found the trial court erred that the County's enforcement of the Ordinance through an injunction would have violated Deep South's substantive due process rights. Accordingly, the Supreme Court reversed the trial court's judgment and remanded for further proceedings. View "Advanced Disposal Services Middle Georgia, LLC v. Deep South Sanitation, LLC" on Justia Law

The trial court certified a class of plaintiffs in this lawsuit against the Department of Human Services. The Department appealed, and in "Deal v. Miller," (739 SE2d 487) (2013)), the Court of Appeals reversed, concluding that the named plaintiffs failed in several respects to show that class certification was warranted. The Supreme Court issued a writ of certiorari to review that decision, and finding no reversible error, affirmed the Court of Appeals. View "Miller v. Deal" on Justia Law

Warden Gregory McLaughlin appealed the grant of a writ of habeas corpus to William Payne. In 2006, Payne was convicted on two counts of aggravated child molestation, three counts of child molestation, and one count of cruelty to children. At trial, then District Attorney for Douglas County, David McDade, appeared as a witness for the State. He identified himself to the jury as the district attorney, identified the examining prosecuting attorney as his assistant, and outlined his duties as district attorney. He also testified that his daughter was a classmate of the victim named in the indictment; his daughter told him what she had heard of the crimes; he participated in an interview of Payne early in the investigation; during the first few days of the investigation, law enforcement efforts were focused on finding Payne; and, that after his interview, he realized he would likely be a witness at trial, and removed himself from Payne's prosecution. Payne appealed, but his convictions were affirmed. In 2009, Payne filed a petition for a writ of habeas corpus, raising, inter alia, a claim of ineffective assistance of appellate counsel. The habeas court found that McDade had a conflict of interest, had testified falsely at trial, and that appellate counsel should have pursued these two issues on appeal. The habeas court also found that had the issues been raised on appeal, the result of Payne's direct appeal would have been different. The court granted the writ of habeas corpus. The warden argued that the habeas court erred in finding that the representation by Payne's appellate counsel was ineffective. The Supreme Court affirmed, finding that the assistant district attorney who acted at trial did so under the authority vested in McDade as the elected district attorney. McDade's disqualifying personal conflict of interest removed that authority, and he was not replaced as provided for by statute. View "McLaughlin v. Payne" on Justia Law

In August 2004, Jimmie Ray Williams filed a pro se petition for habeas corpus alleging, among other claims, that Billy Grantham, his attorney at trial and on direct appeal, provided ineffective assistance of counsel. In 2002, a jury Williams of sexually molesting his 13-year-old stepdaughter and her 14-year-old friend in 2000, after a trial at which his 20-year-old daughter was allowed to testify, as a similar transaction, that Williams touched her sexually four times in one night in 1993, when she was 11 years old and living with him in Florida. The trial court sentenced Williams to serve a total of 20 years in prison followed by 20 years on probation, and the Court of Appeals affirmed. Williams claimed that Grantham conducted a deficient pretrial investigation by failing to obtain Florida court records showing that the alleged similar transaction never took place. Williams argued that if Grantham had conducted a competent investigation and found those records, his daughter’s testimony would have been excluded before trial or successfully impeached at trial, creating a reasonable probability that the trial verdict would have been more favorable to Williams. The habeas court initially denied Williams' petition in November 2006, but in January 2008 the Supreme Court granted his application to appeal and vacated that judgment because the habeas court had not allowed Williams a full and fair opportunity to present his claims. On remand, at a new evidentiary hearing, Williams presented the Florida court records and showed that they were readily available to Grantham at the time of trial. The habeas court entered a detailed order setting aside Williams' convictions. The Warden appealed, arguing, among other things, that reversal was required because the Florida court records on which the habeas court based its finding of ineffective assistance of counsel were never admitted into evidence in the habeas proceedings; the court erred in finding deficient performance; the court erred in finding prejudice based on its erroneous determination that the Florida records amounted to acquittal evidence that collaterally estopped the admission of the similar transaction; and the court erred in finding prejudice because of the "overwhelming evidence" of Williams' guilt, aside from the similar transaction testimony, that was presented at trial. The Supreme Court found that the Florida court records were indeed admitted into evidence at the 2008 habeas hearing, and Court agreed with the habeas court that Grantham's investigation of the alleged similar transaction was professionally deficient. The Warden was correct that the habeas court erred in treating the Florida records as acquittal evidence precluding the admission of the similar transaction testimony, but the Warden was wrong in his assertion that the evidence at Williams' trial, aside from the similar transaction evidence, was overwhelming. The Supreme Court affirmed the habeas court's judgment. View "Humphrey v. Williams" on Justia Law

Derrick Heard appealed his conviction for the murder of Robert Ledbetter. Heard argued on appeal that his constitutional right to a speedy trial was violated; that the trial court erred by allowing two of the State's peremptory strikes; and that the court erred by preventing him from introducing certain evidence about Ledbetter. Finding no reversible error, the Supreme Court affirmed. View "Heard v. Georgia" on Justia Law

Appellant Fredrick Choisnet, Jr. was indicted and tried for murder and related charges in connection with the stabbing death of his elderly father. Appellant pled not guilty by reason of insanity as he was under the delusion that his father was planning to kill him and his mother. The jury found Choisnet guilty but mentally ill, and Choisnet appealed, contending that the trial court's instructions to the jury were erroneous in several ways. Finding no error, the Supreme Court affirmed. View "Choisnet v. Georgia" on Justia Law

Appellee Thomas Nankervis’ was prosecuted for methamphetamine trafficking. After the jury returned a guilty verdict, the trial court held that the methamphetamine trafficking statute was unconstitutional and sentenced Nankervis for manufacturing a controlled substance pursuant to the rule of lenity. The State appealed. The Supreme Court held that the methamphetamine trafficking statute was constitutional and that rule of lenity did not apply in this case. Accordingly, the Court reversed the trial court’s ruling, vacated the judgment in part, and remanded for further proceedings.View "Georgia v. Nankervis" on Justia Law

In August 2010, a City of Norcross police officer stopped Sonia Rodriguez, and found more than four ounces of marijuana in her car. Rodriguez was indicted for possession of marijuana with intent to distribute, and she moved to suppress the discovery of the marijuana, conceding that it was reasonable for the officer to stop and detain her for a brief investigation, but contending that the marijuana was discovered only after her detention was unreasonably prolonged. Following an evidentiary hearing, the trial court denied her motion, but it certified its decision for immediate review, and the Court of Appeals allowed an interlocutory appeal. The appeal eventually was heard by all twelve judges of the Court of Appeals, and although the Court of Appeals entered a judgment affirming the denial of the motion to suppress, only six judges concurred in that judgment. The Supreme Court issued a writ of certiorari to review the Court of Appeals' decision, and after review, concluded that the Court of Appeals never should have rendered any decision in this case and instead should have transferred the appeal to the Supreme Court. Further, the Court saw no error in the denial of the motion to suppress. Accordingly, the Court of Appeals' decision was vacated, the trial court affirmed, and the case remanded for the Court of Appeals to transmit a remittitur to the trial court. View "Rodriguez v. Georgia" on Justia Law