Justia Constitutional Law Opinion Summaries

Appellant Joseph Barnes was found guilty of malice murder in 1993. His conviction was affirmed but his death sentence vacated based on a finding that the trial court improperly restricted the scope of mitigating evidence at sentencing. After remand for resentencing, Appellant moved for a sentencing agreement in exchange for the State's withdrawing the death penalty. In 1999 pursuant to that agreement, Appellant was sentenced to life without parole. Appellant subsequently made a pro se motion for an out-of-time appeal which was denied. He appealed that denial, contending his sentence for malice murder was illegal. In 2012, Appellant asked for appointed counsel to withdraw his plea. Finding that because the sentences were imposed in 1993 and 1999, Appellant's 2012 motion was untimely filed, leaving the trial court without jurisdiction to hear his appeal. The Supreme Court affirmed denial of Appellant's motion. View "Barnes v. Georgia" on Justia Law

David Edenfield was convicted by a jury for murder and several other crimes for his role in the brutal sexual assault and death of six-year-old Christopher Barrios. Edenfield received the death penalty. He unsuccessfully moved for a new trial, and appealed the denial of that motion to the Supreme Court. Finding no reversible error, the Supreme Court affirmed Edenfield's conviction and sentence. View "Edenfield v. Georgia" on Justia Law

Willie Coe was convicted for malice murder, possession of a firearm during the commission of a felony, and possession of a firearm as a convicted felon. He challenged the sufficiency of the evidence presented against him at trial, as well as the trial court's denial of his motion for a mistrial. Finding no reversible error, the Supreme Court affirmed his conviction and sentence. View "Coe v. Georgia" on Justia Law

Appellant Craig Armstead was convicted of murder and related offenses for the stabbing death of a co-worker, Kerri Harris. Appellant's defense at trial was that he was guilty by reason of insanity because he was operating under a delusional compulsion. On appeal to the Supreme Court, Appellant argued the trial court erred when it denied his motion in limine and in allowing certain witnesses to testify at trial. Finding no error, the Supreme Court affirmed the denial of the motion. View "Armstead v. Georgia" on Justia Law

Stephen LaBrellie Rucker appealed his conviction for the aggravated assault and felony murder of Jeremy Kidd. Rucker asserted the trial court erred in failing to grant his motion for mistrial on the ground that the prosecutor improperly inserted his character into evidence and also erred in refusing to permit his trial counsel to impeach a prosecution witness with proof of a pending indictment against him to show the witness’s bias. Rucker also requested that the case be remanded to the trial court for an evidentiary hearing on the issue of alleged ineffective assistance of trial counsel. Finding no error in the trial court's decision, the Supreme Court affirmed. View "Rucker v. Georgia" on Justia Law

After a joint trial, appellants Curtis Billings and Matthew Ross (also known as Matthew Wells) were convicted of murder and other crimes related to the shooting death of Joseph Gunn. Appellants contended that the evidence was insufficient to support their convictions. Upon review, the Supreme Court concluded that the evidence presented at trial was sufficient to authorize a rational jury to find appellants guilty beyond a reasonable doubt of all the crimes of which they were convicted and sentenced. The Court affirmed Billings' conviction and sentence, but vacated Ross's sentence and remanded his case for resentencing. View "Ross v. Georgia" on Justia Law

The trial court in this case ruled that there was no conflict between the 2010 amendment to OCGA 48-5-2 (3) and a 1981 local constitutional amendment providing for the assessment of homestead property in Muscogee County for school and consolidated city-county government taxing purposes. The court further ruled that the 2010 amendment controlled the determination of the fair market value of appellee John Yeoman's recently-purchased homestead property. The Columbus Board of Tax Assessors appeals, but finding no error in the trial court's judgment, the Supreme Court affirmed. View "Columbus Board of Tax Assessors v. Yeoman" on Justia Law

Appellants Atu Lewis and Jacque Dominique Clark were convicted of murder and related crimes stemming from a home invasion. Lewis was sentenced to life in prison without parole for malice murder and a term of years for his other crimes. Clark was sentenced to life in prison with parole for felony murder and a term of years for his remaining crimes. On appeal, Lewis claimed the evidence was insufficient to convict him for malice murder and the other charges for which he was convicted based on the fact that the State's key witness was an accomplice to the crime. Clark claimed the evidence was insufficient to convict him on the basis that key witness' testimony was uncorroborated. Finding the evidence sufficient to authorize a rational jury to find appellants guilty beyond a reasonable doubt of all the crimes of which they were convicted and sentenced, the Supreme Court affirmed both appellants' convictions and sentences. View "Lewis v. Georgia" on Justia Law

In October 2009, a Catoosa County Sheriff's deputy pretending to be a 14-year-old girl named "Tiffany" posted a listing on an internet website indicating she was looking for something fun to do over an upcoming holiday weekend. Appellant Timothy Grube, then a 27-year-old male, responded to the post and subsequently exchanged numerous e-mail communications with undercover officers who were posing as Tiffany. Grube ultimately arranged to meet Tiffany for the purpose of engaging in sexual relations. He was arrested by police when he arrived at the agreed upon meeting place. Grube was indicted on charges of computer pornography, attempted aggravated child molestation and attempted child molestation. The trial court determined all three counts of the indictment were deficient because each failed to identify the victim of the alleged crimes. The State filed a second indictment charging Grube with the same crimes but amended the language used so as to identify the victim as "'Tiffany,' a person believed by the accused to be a child" and "'Tiffany,' a person he believed to be a 14-year-old girl." Grube filed a special demurrer to the second indictment, asserting the indictment failed to again sufficiently identify the victim. The trial court agreed, and the indictment was dismissed. After the Court of Appeals affirmed, the Supreme Court granted the State's petition for certiorari to determine whether the Court of Appeals erred by finding the second indictment insufficient to withstand a special demurrer. Finding that the second indictment satisfied the dual goals of informing the defendant of the charges against him and protecting him from a possible second prosecution for the same offense. Accordingly, Grube's indictment was not subject to the special demurrer and the decision of the Court of Appeals was reversed. View "Georgia v. Grube" on Justia Law

Appellant Dana Meade and Appellee Tim Williamson were the candidates on the ballot in a run-off election in the Democratic primary for Sheriff of Baker County. Meade was the incumbent in the race and was, at the time of the election, serving as Sheriff. Meade was declared the winner by a margin of 39 votes. Williamson contested the results of the election. After a bench trial, the trial court issued an order setting forth findings of fact and reaching the conclusion that sufficient irregularities in voting and in the election process were shown to cast doubt upon the election result. The election was declared invalid and a new election was ordered. The Supreme Court has set aside elections under two different circumstances: where the evidence showed that a sufficient number of electors voted illegally or were irregularly recorded in the contest being challenged to change or cast doubt upon the election; or where systemic irregularities in the process of the election were sufficiently egregious to cast doubt on the result. The evidence presented at trial met neither of these standards. Accordingly, the Supreme Court reversed the trial court's order invalidating the August 21, 2012 run-off election in the Democratic primary for Sheriff of Baker County. View "Meade v. Williamson" on Justia Law