Justia Constitutional Law Opinion Summaries

Tevin Sams was convicted by jury of the malice murder of eight-year-old Jai’mel Anderson, the aggravated assault of six-year-old J. A., and other offenses. The charges arose out of an incident in which shots were fired through an apartment door into a room occupied by the two boys. Following the denial of his motion for new trial, Sams challenged the sufficiency of the evidence supporting his convictions and argued the trial court erred by allowing the State to admit evidence pursuant to OCGA § 24-4-404 (b) that Sams shot at someone else in 2014. Finding no reversible error, the Georgia Supreme Court affirmed Sams’ convictions. View "Sams v. Georgia" on Justia Law

A jury found Mario Talley guilty of the malice murder of Rodney Walker, the aggravated assault and attempted armed robbery of Isiah Knight, and other offenses. Talley appealed the denial of his motion for new trial, arguing that the trial court erred by admitting certain evidence at trial and that his trial counsel provided constitutionally ineffective assistance. After review, the Georgia Supreme Court found no error and affirmed Talley’s convictions. View "Talley v. Georgia" on Justia Law

Claud Lee “Tex” McIver III was convicted of felony murder and other crimes arising out of the 2016 shooting death of his wife, Diane. He appealed, claiming among other things, that the trial court erred in refusing his request to charge the jury on the lesser grade of involuntary manslaughter under OCGA § 16-5-3 (b) and in allowing the State to introduce allegedly inadmissible and prejudicial evidence and make improper comments during closing argument. After review, the Georgia Supreme Court concluded the trial court erred in refusing McIver’s request to charge on the lesser grade of involuntary manslaughter, because the charge was authorized by law and some evidence supported the giving of the charge. Further, the Supreme Court concluded the failure to give the charge was not harmless error, because the Court could not say that it was highly probable that this error did not contribute to the jury’s verdicts. The Court therefore reversed McIver’s convictions for felony murder and possession of a firearm in the commission of a felony. The Court did not decide issues that were unlikely to recur if the State elected to retry McIver, but it did address certain evidentiary issues, and saw no abuse of discretion in admitting some of the challenged evidence, but other evidence lacked relevance or its probative value was substantially outweighed by the danger of unfair prejudice, so that unless the evidentiary posture changed for any retrial, that evidence should not be admitted again. View "McIver v. Georgia" on Justia Law

This case stemmed from the criminal trial of Shalita Jackson Harris, a school bus driver who was convicted of homicide by vehicle in the first degree after the bus she drove crashed, resulting in the death of a student. Following her conviction, Harris moved for new trial alleging that jurors had engaged in misconduct during deliberations by researching the available sentences for her charges. The trial court denied the motion, and the Court of Appeals affirmed. The Georgia Supreme Court found that both the Court of Appeals and trial court applied the wrong legal standards in deciding whether Harris’ claim of juror misconduct was not sufficiently prejudicial to require a new trial. Accordingly, the judgment was vacated and the case remanded for further proceedings. View "Harris v. Georgia" on Justia Law

Ladarrwin Copeland was convicted of malice murder and other crimes in connection with the shooting deaths of Timothy Rodgers and Ricky Johnson. On appeal, Copeland argued the trial court lacked jurisdiction to try his case , that the evidence was insufficient to sustain his convictions, and that the trial court erred in denying his motion to suppress evidence related to the search of his cell phone records. After review, the Georgia Supreme Court found no reversible error and affirmed the trial court. View "Copeland v. Georgia" on Justia Law

Jerome Mobley was convicted by jury of breaking into his estranged wife’s home, in violation of a condition of pretrial bond, and shooting and killing her in the presence of the couple’s children. Mobley contended the trial court erred by refusing a jury instruction on voluntary manslaughter was warranted by at least slight evidence of sudden provocation. Because a voluntary manslaughter instruction was not warranted by the evidence, the Georgia Supreme Court affirmed. View "Mobley v. Georgia" on Justia Law

Joe Rayton was convicted by jury of murder for the shooting death of Antonio Ladson. On appeal, Rayton contended the trial court erred by refusing his request for a jury instruction on voluntary manslaughter. Additionally, Rayton argued he was denied effective assistance of counsel by his trial counsel’s objection to a jury instruction requested by the State regarding accomplice corroboration and by counsel’s failure to object to the prosecutor’s statement during closing argument that Rayton’s own testimony admitting that he shot Ladson during an attempted drug deal precluded a self -defense verdict. After review, the Georgia Supreme Court found no reversible error and affirmed the trial court. View "Rayton v. Georgia" on Justia Law

Andre Byrd was convicted by jury of malice murder and other crimes in connection with the shooting death of David McReynolds. On appeal, Byrd contended only that the trial court erred by granting the State’s challenge to his peremptory strikes of three prospective jurors and by reseating those jurors. After review, the Georgia Supreme Court found no reversible error and affirmed the trial court. View "Byrd v. Georgia" on Justia Law

Hector Garay was convicted by jury of malice murder and other crimes in connection with the January 1996 shooting death of Adalberto Salinas. In his only enumeration of error on appeal, he contended there was insufficient evidence to prove him guilty of the crimes charged beyond a reasonable doubt. The Georgia Supreme Court disagreed and affirmed Garay’s convictions. View "Garay v. Georgia" on Justia Law

Appellant Justin Harris left his 22-month-old son Cooper strapped in his rear-facing car seat on a June 2014. Harris walked into work; the child died of hyperthermia after hours in the hot car. The State’s theory was that Appellant intentionally and maliciously abandoned his child to die a slow and painful death trapped in the summer heat, so that Appellant could achieve his dream of being free to further his sexual relationships with women he met online. The defense theory was that Appellant was a loving father who had never mistreated Cooper and simply but tragically forgot that he had not dropped off the child on that particular morning. During Appellant’s trial, substantial evidence was presented to support both theories. At issue is some of the State’s evidence which was admitted at trial that “did little if anything to answer the key question of Appellant’s intent when he walked away from Cooper, but was likely to lead the jurors to conclude that Appellant was the kind of man who would engage in other morally repulsive conduct. The Georgia Supreme Court found that the evidence presented was legally sufficient to support his convictions for the crimes against Cooper, and some of the evidence was properly admitted as intrinsic evidence to establish the State’s motive theory, the trial court should have excluded much of it because it was needlessly cumulative and prejudicial. Appellant’s convictions on counts charging crimes against Cooper were reversed. View "Harris v. Georgia" on Justia Law