Justia Constitutional Law Opinion Summaries

Appellant Melvin Browder appealed his conviction and sentence for the murder of Eboni Galloway, aggravated assault of two other victims by discharging a firearm from within a motor vehicle toward a person, and possession of a firearm during the commission of a felony. On appeal, he argued: (1) the evidence was insufficient to support a conviction of murder or aggravated assault; (2) the trial court erred by failing to give requested charges on involuntary manslaughter as a lesser included offense of the murder charge; (3) the trial court erred by admitting out of court statements made by the co-defendant; and (4) the trial court erred in denying his motion for new trial on the ground that he received ineffective assistance of counsel at the trial. Finding no reversible error, the Supreme Court affirmed the trial court in all respects. View "Browder v. Georgia" on Justia Law

Appellant Rashad Bester appealed his convictions for malice murder and other crimes relating to the strangulation death of Shawna Webber. He claimed that the trial court erred in denying his claim that his trial counsel provided ineffective assistance and his claim that the prosecutor violated his equal protection rights by the use of a peremptory strike in selecting the jury. The Supreme Court affirmed Bester's convictions for malice murder and sodomy, but vacated his conviction and sentence for aggravated assault, because that conviction merged with malice murder. View "Bester v. Georgia" on Justia Law

Appellant Robert Alexander was sentenced to life without parole for the felony murder of two-year-old Diamone Wilson. He appealed his conviction and the denial of his motion for new trial in which he asserted the trial court erred by limiting the scope of voir dire and improperly commenting on the evidence. Finding no reversible error, the Supreme Court affirmed. View "Alexander v. Georgia" on Justia Law

Appellee Steven Wilson is a licensed optometrist, providing eye care services in Lowndes County as Wilson Eye Center (“WEC”). Appellees Cynthia McMurray, Jodie E. Summers, and David Price are also licensed optometrists employed by WEC. Prior to 2010, Spectera, Inc. had entered provider contracts ("Patriot contracts") with Wilson and McMurray and they became members of Spectera's panel of eye care providers. Summers was already on Spectera's panel of eye care providers. Under the Patriot contract, Spectera would reimburse appellees for the materials Spectera insureds used from WEC's inventory by paying appellees a fee for their materials' costs and by having Spectera insureds remit a materials copayment to appellees. Spectera decided to terminate its Patriot contracts and replace them with independent participating provider (IPP) agreements. After the trial court temporarily enjoined Spectera from enforcing its IPP agreement, Spectera sought to remove appellees Wilson, Summers, and McMurray from its approved panel of providers. The trial court enjoined Spectera from taking such action. Although Price was not on Spectera's provider panel, he alleged Spectera violated Georgia law by denying him membership on its panel because of his refusal to sign the IPP agreement. Upon considering the parties' cross motions for summary judgment, the trial court granted issued a permanent injunction precluding Spectera from enforcing the restrictions contained in the IPP agreement as to "any other licensed eye care provider on [Spectera's] provider panel" or those who had applied for admittance to the panel. Spectera appealed the trial court's decision to the Court of Appeals which affirmed in part and reversed in part. Upon review of Spectera's appeal, the Supreme Court concluded a portion of the IPP agreement violated Georgia law, and therefore sustained the Court of Appeals in one respect. However, because the IPP agreement did create the type of impermissible discrimination between classes of licensed eye care providers contemplated by the applicable law, the Court of Appeals was incorrect in concluding that the IPP agreement violated that particular subsection of the applicable law. Furthermore, the termination of any outstanding contracts with appellees Wilson, McMurray, and Summers should have been based on the lawful terms stated in the contracts and not based on a permanent court injunction. Therefore, the Supreme Court affirmed in part, reversed in part and remanded the case for further proceedings. View "Spectera, Inc. v. Wilson" on Justia Law

This case stemmed from an effort by Mortgage Alliance Corporation (“MAC”) a residential subdivision called "Silverstone." In August 2008, MAC sued the county and various county officials alleging, among other things, that an August 2006 letter to MAC from the county's sole commissioner, which said that the county's position was that any proposal to develop MAC's property as a subdivision would need to comply with a recent amendment to the county's land use ordinances, resulted in a taking of MAC's property without just compensation. The trial court granted summary judgment to the defendants on the ground that MAC's complaint was untimely. The Court of Appeals affirmed, and the Supreme Court granted MAC's petition for certiorari. Upon review, the Supreme Court concluded that this case was resolved on the ground that the August 2006 Letter was not a “decision” within the meaning of the applicable statute, and the county never made a final decision on MAC's Silverstone proposal. Consequently, MAC's inverse condemnation claim never ripened for judicial review, and the trial court should have granted summary judgment to the defendants on this ground. Although the trial court and the Court of Appeals erred in concluding there was an appealable decision, they reached the right result, and therefore the Court affirmed the appellate court's judgment. View "Mortgage Alliance Corp. v. Pickens County" on Justia Law

Appellant David Banks Brett appealed his conviction for the shooting death of Jose Garcia-Castro. In his motion for new trial, appellant alleged his trial counsel rendered ineffective assistance, but the trial court denied the motion, finding appellant had failed to show counsel’s performance was deficient. On appeal, appellant maintained his ineffective assistance claim, arguing that counsel failed to object to inadmissible hearsay and failed to appreciate and “adapt” the defenses available to his client during trial. Finding that that trial court did not err in denying Brett's motion for a new trial, the Supreme Court affirmed his convictions. View "Brett v. Georgia" on Justia Law

Following a jury trial, Anastasia Jackson was found guilty of felony murder, armed robbery, two counts of aggravated assault with a deadly weapon, criminal attempt to commit armed robbery, conspiracy to commit armed robbery, and possession of a firearm during the commission of a felony. On appeal, she contended that the trial court failed to instruct the jury on the corroboration of accomplice witness testimony, that she was prohibited from exploring the bias of one of the State’s witnesses, that trial counsel rendered ineffective assistance, and that the evidence was insufficient to support the verdict. Finding no error at trial, and that Jackson did not prove she received ineffective assistance of trial counsel, the Supreme Court affirmed. View "Jackson v. Georgia" on Justia Law

Jarmarvis Dixon appealed his convictions and sentences for malice murder, and other crimes associated with that killing. Dixon moved to exclude evidence of a police interview, contending that it was conducted in violation of what he claims was a previously-invoked right to counsel. In addition, Dixon contended that counsel was ineffective in not objecting to a remark during the State’s opening statement. Finding no error at trial, and that Dixon did not prove he received ineffective assistance of counsel, the Supreme Court affirmed. View "Dixon v. Georgia" on Justia Law

Appellant Edward Morris was convicted of murder, aggravated assault, criminal street gang activity, and related offenses in connection with incidents involving two victims in May and June of 2007. Morris appealed his conviction, contending that the trial court erred by refusing to sever a particular count from the others at trial and by admitting certain expert testimony, and that the State failed to prove venue. Finding no error, the Supreme Court affirmed. View "Morris v. Georgia" on Justia Law

Appellant Jarvis Matthews was found guilty of malice murder and other crimes in connection with the shooting death of Juan Manuel Ramirez. Appellant contended on appeal that the trial court erred by: (1) admitting his sentencing order from a prior conviction; (2) admitting similar transaction evidence (allowing the State to urge the jury to use the evidence to prove Appellant’s character, and improperly instructing the jury regarding its use); and (3) preventing Appellant from presenting evidence implicating another person in the crimes. Finding no error, the Supreme Court affirmed. View "Matthews v. Georgia" on Justia Law