Justia Constitutional Law Opinion Summaries

Appellant Robert Annunziata was convicted by jury of malice murder and other crimes in connection with a 2019 shooting that took place outside of a nightclub that resulted in the death of John Price and injuries to Washington Young and Andrew Darling. On appeal, Appellant contended the trial court erred in refusing to instruct the jury on voluntary manslaughter. Finding no reversible error, the Georgia Supreme Court affirmed. View "Annunziata v. Georgia" on Justia Law

Appellant Ricardo Beltran-Gonzales appealed his conviction for malice murder in connection with a 2013 stabbing at Hays State Prison, which resulted in the death of fellow inmate Nathaniel Reynolds. On appeal, Appellant contended the trial court abused its discretion in recharging the jury on malice murder without also recharging the jury on Appellant’s defenses. Appellant also argued his trial counsel was ineffective for failing to object to the State jointly trying Appellant with another inmate, Leonardo Ramos Rodrigues, who was separately charged with committing the same fatal stabbing. Finding no reversible error, the Georgia Supreme Court affirmed. View "Beltran-Gonzales v. Georgia" on Justia Law

Joshua DeMuro was convicted by jury of murder in the 2018 shooting death of Kevin Gilman. DeMuro challenged the sufficiency of the evidence and contended the State failed to prove beyond a reasonable doubt that the fatal shooting was not justified. DeMuro also argued the trial court gave incomplete jury instructions on witness credibility, impeachment, and justification and that the trial court erred in refusing to send written jury instructions out with the jury. Finding no reversible error, the Georgia Supreme Court affirmed. View "DeMuro v. Georgia" on Justia Law

James Randolph was convicted by jury of malice murder, armed robbery, and other crimes in connection with the 2000 armed robbery of Carlos Torres and Dennis Dixon and the shooting death of Rodney Castlin. On appeal, Randolph argued the evidence was insufficient to support his convictions because the State failed to corroborate the testimony of an accomplice and that the trial court erred in admitting evidence of two other acts under OCGA § 24-4-404 (b). Because the Georgia Supreme Court concluded that the accomplice’s testimony was sufficiently corroborated by other evidence admitted at trial, that the trial court did not err in admitting one prior incident of armed robbery, and that any error in admitting the other incident (a home burglary) was harmless, the judgment of conviction was affirmed. View "Randolph v. Georgia" on Justia Law

Joseph Jackson appealed his malice murder conviction for the 2018 stabbing death of Claudine Hargrove. Jackson argued: (1) the trial court erred in failing to take curative action after the prosecutor commented on his post-arrest silence by questioning him about why he waited until trial to assert that he acted in self-defense; (2) trial counsel was ineffective for failing to move for a mistrial after this questioning; and (3) the cumulative harm from these errors warranted a new trial. Given the overwhelming evidence of guilt, the Georgia Supreme Court concluded any error by the trial court in failing to take some corrective action was harmless, trial counsel was not deficient in failing to move for a mistrial because such a motion would have been futile, and there were not multiple errors to assess cumulatively. Therefore, judgment of conviction was affirmed. View "Jackson v. Georgia" on Justia Law

Appellant Steven Whittaker was convicted of malice murder and related crimes in connection with the 2018 stabbing death of LeBron Hankins. On appeal, Whittaker contended: (1) the evidence was insufficient to sustain his convictions for malice and felony murder; (2) the trial court committed plain error by failing to instruct the jury that Whittaker had no duty to retreat; (3) trial counsel gave constitutionally ineffective assistance in a number of ways; and (4) the trial court erred by failing to enter an order vacating the sentence for felony murder. The Georgia Supreme Court found, after review of the trial court record, the evidence was sufficient to support his malice-murder conviction, and his sufficiency challenge as to his felony-murder conviction was moot because he was not sentenced on that count. The Court also found the trial court did not err by failing to instruct the jury that Whittaker had no duty to retreat because retreat was not placed at issue. Whittaker’s counsel did not perform deficiently in any of the ways Whittaker asserts. And although the felony-murder count should have been vacated by operation of law, there was no sentencing error to correct because the error would have no actual effect on Whittaker’s sentence. So the Supreme Court affirmed Whittaker’s convictions and sentence. View "Whittaker v. Georgia" on Justia Law

Norris Owens was convicted by jury of felony murder based on possession of a firearm by a first-offender probationer and other crimes in connection with the shooting death of Randolph Williamson. On appeal, Owens argued the trial court erred by not merging the count for felony murder based on unlawful possession of a firearm by a first-offender probationer into the voluntary manslaughter verdict. Seeing no error, the Georgia Supreme Court affirmed. View "Owens v. Georgia" on Justia Law

Tony Locklear was convicted by jury of the malice murder of William Long, concealing a death, and related charges. On appeal, Locklear challenged the sufficiency of the evidence supporting his convictions. He also argued that the trial court erred by: (1) failing to suppress statements made during his custodial interview; (2) denying his motion to suppress certain physical evidence; (3) providing a confusing verdict form to the jury; and (4) refusing to grant a mistrial after the prosecutor made improper comments during closing arguments. Because the evidence was clearly sufficient to support Locklear’s convictions and because the trial court committed no reversible error with respect to Locklear’s other enumerations of error, the Georgia Supreme Court affirmed. View "Locklear v. Georgia" on Justia Law

Appellant Quentin Jackson was convicted of malice murder and related charges in connection with the shooting death of Darian Brewster. On appeal, Jackson argued: (1) the evidence was insufficient; (2) his trial counsel provided constitutionally ineffective assistance in several respects; and (3) the trial court erred by failing to instruct the jury on accomplice corroboration. The Georgia Supreme Court found no reversible errors and affirmed the convictions. View "Jackson v. Georgia" on Justia Law

Appellant Jerrontae Morris was convicted of malice murder and related crimes in connection with the November 2015 shooting of a vehicle occupied by Anthony Lundy and Demeco Person, which fatally wounded Lundy. On appeal, Appellant contended the evidence was insufficient as a matter of constitutional due process to sustain his conviction for malice murder because the State failed to prove that Appellant proximately caused the victim’s death and did not prove that Appellant either conspired with his co-defendants to commit the crime or was a party to the crime. Appellant also contends that the evidence was insufficient as a matter of Georgia statutory law to sustain his conviction for malice murder because the trial evidence was circumstantial and the State failed to exclude every reasonable hypothesis other than his guilt. The Georgia Supreme Court found no reversible errors and affirmed the convictions. View "Morris v. Georgia" on Justia Law