Justia Constitutional Law Opinion Summaries

In 2013, Cory Butler was convicted at a bench trial for malice murder and other crimes relating to a 2009 home invasion and beatings that resulted in the death of Epsie Ewing and injury of her husband, C.F. Ewing. On appeal, Butler argued: appeal: 1) the evidence presented at trial was insufficient to support his conviction for malice murder; (2) the trial court did not determine whether Butler knowingly and intelligently waived his right to a jury trial; (3) Butler received constitutionally ineffective assistance of counsel; and (4) the trial court committed a sentencing error. Finding no reversible error, the Georgia Supreme Court affirmed. View "Butler v. Georgia" on Justia Law

Appellant Darrall Early was convicted of felony murder and aggravated assault in connection with the 2019 shooting death of Ramonte Harris. In his appeal, Early contended the trial court erred by admitting a jail video recording into evidence, and by failing to merge the aggravated assault count when sentencing him. Finding no merit in these contentions, the Georgia Supreme Court affirmed. View "Early v. Georgia" on Justia Law

Willie Caldwell appealed his conviction for felony murder arising out of the 2008 shooting death of Ricardo McPherson. On appeal, Caldwell claimed the evidence presented at his trial was insufficient to sustain his conviction because a key witness was an accomplice, and her testimony was not corroborated. Further, Caldwell argued the trial court erred by failing to give a curative instruction after the District Attorney’s prejudicial closing argument . Although the Georgia Supreme Court concluded the evidence was sufficient under the accomplice-corroboration statute to convict, the Court determined the trial court should have provided a curative instruction for the District Attorney’s erroneous argument, and that the error was harmful. Accordingly, judgment was reversed and the matter remanded for further proceedings. View "Caldwell v. Georgia" on Justia Law

Jordan Harris appealed his convictions for felony murder and other charges stemming from the July 2010 shooting of Walter Phelps during the robbery of Phelps’s store; Phelps died from blood clots over a month after the shooting. Harris argued: (1) the evidence presented at his trial was insufficient to support his convictions; and (2) the trial court erred by admitting other –acts evidence, unreliable identifications of him, evidence marred by violations of Brady and Georgia’s criminal discovery statute, and inadmissible hearsay. The Georgia Supreme Court found the evidence sufficient, there was no abuse of the trial court’s discretion in admitting the other-acts evidence, there was not a showing of a Brady violation (and the claim was waived under the discovery statute), and any error admitting hearsay was harmless. View "Harris v. Georgia" on Justia Law

Francisco Palencia was convicted of several offenses arising from a home invasion and sexual assault of V. M. Palencia appealed his convictions to the Court of Appeals, which affirmed. Palencia thereafter filed a petition for a writ of certiorari to the Georgia Supreme Court, arguing that the Court of Appeals erred by determining that the trial court did not plainly err by failing to charge the jury on the requirement under OCGA 24-14-8 that accomplice testimony be corroborated. After review, the Supreme Court held that the Court of Appeals incorrectly distinguished the Supreme Court’s binding precedent in reaching its decision. Accordingly, the Court granted Palencia’s petition for certiorari, reversed in part the Court of Appeals’ judgment, and remanded this case to the appellate court for further proceedings. View "Palencia v. Georgia" on Justia Law

Appellant David Renfro challenges his 2019 convictions for malice murder and other crimes in connection with the shooting death of Rita Hennon. Appealing his conviction and sentence, Renfro argued the trial court erred in admitting his pre-arrest statements to police because he was allegedly under custodial interrogation and had not yet received Miranda warnings. Finding that any error in admitting Renfro’s statement was harmless beyond a reasonable doubt, the Georgia Supreme Court affirmed. View "Renfro v. Georgia" on Justia Law

The Georgia Supreme Court granted Gregory Davenport’s application for a certificate of probable cause to appeal the denial of his petition for a writ of habeas corpus. Davenport asked whether the habeas court erred in finding that a count of aggravated assault predicated on the use of a deadly weapon did not merge with his conviction for armed robbery. The Georgia Supreme Court concluded that the habeas court indeed erred with respect to that question, and reversed judgment in part. View "Davenport v. Ward" on Justia Law

Appellant Kaovion Dickey challenged his convictions for malice murder and other crimes in connection with the 2018 shooting death of Tony McGowan and the shooting of Mikeem Jackson. Appellant’s sole enumeration of error was that the evidence was legally insufficient to support his convictions. The Georgia Supreme Court found the evidence was sufficient for the jury to conclude that Appellant was guilty, so judgment was affirmed. View "Dickey v. Georgia" on Justia Law

Following the Georgia Supreme Court’s grant of his application for discretionary appeal, Donnel Rawls appealed the trial court’s denial of his motion seeking a copy of his trial transcripts at public expense. Based on the Supreme Court’s review of the record, the parties’ briefs, and the representations of counsel at oral argument, Rawls obtained the relief he sought. Rawls’s appeal therefore became moot and was therefore dismissed. View "Rawls v. Georgia" on Justia Law

Jared Smith was convicted of malice murder and theft by taking in connection with the 2018 stabbing death of Ronald Roach. Smith’s sole contention on appeal was that the trial court erred in allowing the medical examiner to provide expert opinion testimony about blood-spatter evidence depicted in photographs of the crime scene. Seeing no reversible error, the Georgia Supreme Court affirmed. View "Smith v. Georgia" on Justia Law