Justia Constitutional Law Opinion Summaries

After a joint trial, Demetre Mason and Frankland Henderson were convicted of malice murder and other crimes in connection with the 2014 shooting deaths of Sonia Williams and Shaniqua Camacho. On appeal, Mason contended the evidence was not sufficient to support his convictions for malice murder, and that the trial court should have held a hearing to determine whether evidence that, a month before the murders, Mason stole a handgun that was used in the shootings was admissible under Rule 403. In a separate appeal, Henderson raised six claims: (1) the admission at trial of Mason’s out-of-court statement to police violated Henderson’s rights under the Confrontation Clause of the Sixth Amendment; (2) the trial court should have given an instruction limiting how the jury could consider Mason’s out-of-court statement; (3) the testimony of one witness for the prosecution, who he claimed was an accomplice, was insufficiently corroborated; (4) the trial court should have excluded as hearsay testimony about statements from an associate of Henderson and Mason, because there was insufficient evidence to show that the statements were made in furtherance of a conspiracy so as to fall within a hearsay exception; (5) the trial court abused its discretion in denying Henderson’s motion to sever his case; and (6) the trial court abused its discretion in admitting photos of Henderson making gang signs without proper authentication.The Georgia Supreme Court found no reversible errors in either case and affirmed the convictions. View "Henderson v. Georgia" on Justia Law

Larry Reese was convicted by jury of the 2015 malice murder of Claynesia Ringer, possession of a firearm during the commission of a felony based on shooting Ringer, and possession of marijuana with intent to distribute. Reese argued on appeal: (1) the trial court plainly erred by failing to instruct the jury on justification, no duty to retreat, and the State’s burden to disprove affirmative defenses; (2) the trial court plainly erred by not giving an accomplice corroboration charge; and (3) Reese received constitutionally ineffective assistance of counsel. Seeing no error, the Georgia Supreme Court affirmed. View "Reese v. Georgia" on Justia Law

Tomarkus Young was convicted by jury of felony murder and other charges in connection with the 2018 shooting death of Richard Anderson. On appeal, Young argued the evidence was constitutionally insufficient to support his convictions; that the trial court erred in denying his motion to strike a potential juror; that he received ineffective assistance of counsel; and that cumulative errors require the grant of a new trial. Finding these assertions lacked merit, the Georgia Supreme Court affirmed. View "Young v. Georgia" on Justia Law

Joshua Moulder was convicted of malice murder, armed robbery, and possession of a firearm during the commission of a felony in connection with the July 2006 shooting death of Anthony Rudolph and was also convicted of influencing a witness in 2014. He appealed, arguing the evidence was not sufficient to support his convictions related to the 2006 shooting and that counsel provided ineffective assistance by: not arguing that the State failed to prove the statute of limitation tolling provision alleged for the non-murder crimes committed in 2006; failing to raise a hearsay and Confrontation Clause objection to certain testimony given by the lead detective; failing to correctly advise Moulder about whether his prior convictions could be used to impeach him if he testified; inaccurately describing the reasonable-doubt standard in closing argument; and failing to object to a jury charge about statements made during formal court proceedings. Because the evidence was sufficient to support Moulder’s convictions and he has failed to prove his claims of ineffective assistance of counsel, the Georgia Supreme Court affirmed. View "Moulder v. Georgia" on Justia Law

Perry Lee Hatcher, Jr., was convicted by jury of felony murder and cruelty to children in the third degree in connection with the shooting death of his wife, Dashea Hatcher, in the presence of their son, M. H. Hatcher contended his attorney was ineffective for failing to object to the qualifications of the State’s expert witness and to rebut the expert’s opinion concerning fibers found on the murder weapon. Because Hatcher failed to carry his burden of showing ineffective assistance of counsel, The Georgia Supreme Court affirmed the trial court’s order denying his motion for a new trial. View "Hatcher v. Georgia" on Justia Law

Appellant Bobby Wood, Jr. was convicted of felony murder in connection with the 2020 shooting death of Aaron Skinner. On appeal, Appellant contended: (1) the trial court abused its discretion in denying him the opportunity to cross-examine the State’s expert witness about Skinner’s alleged arrest for criminal trespass on the day before the shooting; (2) the trial court violated his right to due process by denying him access to certain physical evidence post-trial; (3) trial counsel was ineffective for failing to object to the State’s redirect examination of the State’s expert witness as outside the scope of redirect examination; and (4) the cumulative effect of the alleged errors committed by the trial court and trial counsel deprived Appellant of a fair trial. Finding no reversible error, the Georgia Supreme Court affirmed. View "Wood v. Georgia" on Justia Law

Sean Allen appealed his conviction for felony murder for the 2021 shooting death of Daquan Gillett. Allen argued: (1) the trial court erred when it failed to grant him immunity from prosecution based on self-defense; (2) the evidence presented at trial was insufficient to support his conviction; (3) the trial court erred by limiting his ability to argue the law of self-defense in closing argument; and (4) trial counsel was ineffective in several respects. Finding no reversible error, the Georgia Supreme Court affirmed. View "Allen v. Georgia" on Justia Law

Patrick Middleton moved to suppress evidence obtained during a search by Officer Amanda Graw of the Kingsland Police Department (“KPD”), arguing that she did not have authority to stop or search him because she was outside the territorial jurisdiction of the KPD. Officer Graw claimed that she did have authority to perform the stop and search because she had been deputized by the Camden County Sheriff’s Office (“CCSO”) seven years earlier. After the trial court granted the motion to suppress, the State appealed. The Court of Appeals reversed, concluding that Officer Graw had presented sufficient evidence of her deputization. After its review, the Georgia Supreme Court vacated the Court of Appeals’ opinion with direction that it vacate the trial court’s order and remand the case to the trial court with direction to clarify its basis for ruling that the search and seizure of Middleton was unlawful. View "Middleton v. Georgia" on Justia Law

In 2009, a jury convicted David Edenfield for the 2007 sexual assault and murder of six-year-old Christopher Barrios, and the jury imposed a death sentence for the murder. Lead trial counsel, joined by other attorneys, represented Edenfield on direct appeal, and, in June of 2013, the Georgia Supreme Court affirmed Edenfield’s convictions and sentences on direct appeal. Edenfield subsequently filed a petition for a writ of habeas corpus, asserting he was ineligible for the death penalty because he is intellectually disabled and that trial counsel provided constitutionally ineffective assistance during his trial in several ways, including by failing to present evidence of Edenfield’s alleged intellectual disability in the sentencing phase as mitigating evidence. He also contended that appellate counsel had provided ineffective assistance. The habeas court denied relief on all claims except for the ineffective assistance of trial counsel claim concerning counsel’s presentation of evidence of Edenfield’s alleged intellectual disability as mitigating evidence in the sentencing phase. Based on that claim, the habeas court vacated Edenfield’s death sentence. The Warden appealed in Case No. S23A0260, and Edenfield has cross-appealed in Case No. S23X0261. In the Warden’s appeal, the Georgia Supreme Court reversed the habeas court’s decision to vacate Edenfield’s death sentence. In Edenfield’s cross-appeal, the Court affirmed in part; the Court conclude as to Edenfield’s claim regarding trial counsel’s alleged deficiency concerning certain allegedly mitigating circumstances that additional findings of fact and conclusions of law were required, and the case was therefore remanded to the habeas court for further proceedings. View "Caldwell v. Edenfield" on Justia Law

Jose Basulto appealed his convictions for felony murder and aggravated assault stemming from an incident in which he drove his truck into several pedestrians after a bar fight. Basulto’s actions resulted in the deaths of two of the pedestrians, and left a third seriously injured. Basulto’s only argument on appeal was that the trial court erred by refusing to remove a juror who revealed new information about the juror’s criminal history after being selected for the jury. Because it found the trial court did not abuse its discretion in failing to remove the juror, the Georgia Supreme Court affirmed. View "Basulto v. Georgia" on Justia Law