Justia Constitutional Law Opinion Summaries

Defendant appealed his convictions for malice murder and possession of a firearm during the commission of a felony in connection with the fatal shooting of the victim. Defendant challenged his conviction on multiple grounds: that the evidence was insufficient to support the verdicts; that the prosecutor made improper statements in closing argument; that the trial court failed to cure the prejudice resulting from the prosecutor's improper statements; that a witness's immunity agreement was improperly sent to the jury during deliberations; that the trial court twice delivered improper Allen charges to the jury; that the trial court provided incomplete instructions regarding aggravated assault and the defense of alibi; that the trial court rendered ineffective assistance; and that the trial court erred in denying his motion for new trial. The court found the challenges were without merit and affirmed the judgment.

Defendant was indicted for the malice murder of the victim, an alternative count of felony murder during the commission of aggravated assault, and the aggravated assault and battery of the victim's sister. After a jury trial, defendant was acquitted of malice murder and found guilty of the remaining counts. A motion for new trial was denied, but the trial court vacated the sentence for aggravated assault pursuant to a concession by the state. The court rejected defendant's claims on appeal that the felony murder count on the indictment failed to allege the essential elements of the predicate offense of aggravated assault; that the trail court erred in admitting evidence of a similar transaction; and that his trial counsel rendered ineffective assistance. Accordingly, the court affirmed the judgment.

Defendant was convicted of two counts of murder and related crimes in connection with the shooting deaths of two victims. Defendant appealed the denial of his motion for a new trial, alleging reversible error in certain jury instructions and in the trial court's failure to merge several of his convictions. The court found no error in the jury charge but vacated one count of aggravated assault, which should have been merged into the malice murder conviction.

Defendant appealed his conviction for malice murder, felony murder, aggravated assault, and tampering with evidence. Defendant contended that the evidence was insufficient to support the verdict and the trial court erred by admitting similar transaction evidence. The court held that the evidence was sufficient to enable the jury to find defendant guilty of the crimes for which he was convicted beyond a reasonable doubt. The court also held that the trial court did not err in admitting evidence of defendant's prior conviction for arson where the State offered the evidence to show defendant's bent of mind or course of conduct in using escalating degrees of violence toward women. Accordingly, the court affirmed the judgment.

Defendant was convicted of the malice murder and aggravated assault of his wife and sentenced to life in prison. Defendant appealed the denial of his motion for a new trial, asserting that the trial court erred by admitting similar transaction evidence and evidence of statements made by the victim regarding prior difficulties. The court concluded that any prejudice from the age of the similar transactions evidence at issue was outweighed by the probative value of the evidence. The court also concluded that there was no error in admitting the testimony of defendant's cell-mate because the evidence was sufficient to establish the required similarity between the charged crimes and the attack on the cellmate and was probative of defendant's bent of mind and course of conduct. The court did not err in permitting several witnesses to testify about the statements the victim made pertaining to prior difficulties between defendant and the victim where the hearsay testimony was either admissible under the necessity exception to the hearsay rule or its admission constituted harmless error. Accordingly, the court affirmed the judgment.

Defendant appealed his conviction for felony murder, aggravated assault, and possession of a knife during the commission of a crime. The court rejected defendant's claims that trial counsel rendered ineffective assistance of counsel by introducing into evidence his videotaped statement to police without first redacting where he invoked his right to counsel and him asking God to have mercy on his soul; that the trial court erred by truncating his testimony that he was actually afraid of the victim and only acted in self-defense; that the trial court erred by not reading aloud to the jurors two stipulations agreed upon by the parties; that the trial court erred by failing to suppress his statement to an arresting officer that he had consumed seven alcoholic beverages on the night of the murder; and that the trial court erred by not instructing the jury regarding Miranda and the voluntariness of statements. Accordingly, the court affirmed the judgment.

Defendant was convicted of felony murder and acquitted of malice murder in connection with the shooting death of the victim. On appeal, defendant contended that the evidence at trial was insufficient to support the jury's verdict. The court affirmed the judgment and held that the evidence was sufficient to enable a rational trier of fact to find defendant guilty of felony murder beyond a reasonable doubt.

Defendant appealed his conviction for felony murder, aggravated assault, and possession of a firearm during the commission of a felony, contending, among other things, that the trial court incorrectly charged the jury and that he received ineffective assistance of counsel. The court rejected defendant's claim of error regarding the jury charge where trial courts did not have to follow an exact formula in instructing juries so long as the charge as a whole ensured that the jury would consider whether the evidence of provocation and passion might authorize a verdict of voluntary manslaughter. The court also rejected defendant's claims of ineffective assistance of counsel where defendant himself placed the evidence at issue before the jury and where trial counsel did not render ineffective assistance by failing to object to a proper argument. Accordingly, the judgment was affirmed.

Defendant appealed his conviction for malice murder, aggravated assault, and possession of a firearm during the commission of a crime, contending that a co-defendant's statement was introduced into evidence in violation of Crawford v. Washington. The State correctly conceded that the co-defendant's statement to police during the investigation of the victim's murder was testimonial in nature and that it was improperly admitted because defendant could not confront the co-defendant, who died before the trial commenced. Under the facts of the case, however, this Crawford violation was harmless where the co-defendant's statement was cumulative of other properly admitted evidence. Accordingly, the judgment was affirmed.

Defendant was convicted of felony murder and other related offenses in connection with the shooting death of the victim. On appeal, defendant claimed that the trial court erred in denying his Batson challenge to the State's peremptory strikes during jury selection and violated his Fourteenth Amendment Equal Protection rights relating to jury selection. The court held that a trial court's finding as to whether the opponent of a strike has proven discriminatory intent was entitled to great deference and would not be disturbed unless clearly erroneous. Applying this standard, defendant's contention that the State failed to give an adequate nondiscriminatory reason for striking Juror 24 was unpersuasive. Accordingly, the judgment was affirmed.