Justia Constitutional Law Opinion Summaries

Milo Blaine Whitetail was convicted by jury of intentional or knowing murder. Whitetail argued on appeal the evidence is insufficient to prove that he was not in a dissociative mental state at the time of the murder due to his post-traumatic stress disorder. Whitetail also argued the State did not prove he acted knowingly or intentionally. Finding no reversible error, the North Dakota Supreme Court affirmed. View "North Dakota v. Whitetail" on Justia Law

Dean Hatzenbuehler appealed an order revoking sentencing and judgment imposing a new sentence. In August 2022, Hatzenbuehler pled guilty to conspiracy to deliver a controlled substance, a class B felony; delivery of a controlled substance, a class B felony; possession of a controlled substance-methamphetamine, a class A misdemeanor; and possession of drug paraphernalia, a class A misdemeanor He argued the district court’s findings of fact on the revocation of his probation were clearly erroneous and the court erred by not adequately considering the statutory sentencing factors. The North Dakota concluded the court’s findings supporting revocation were not clearly erroneous, the court adequately considered the statutory factors, and the court did not abuse its discretion in imposing a sentence upon revocation. View "North Dakota v. Hatzenbuehler" on Justia Law

Appellant Reginald Maynor appealed his convictions for felony murder predicated on aggravated assault and other crimes related to the 2015 shooting death of Marti Stegall, Sr. This case stemmed from f a romantic affair involving two couples residing in the Trestle Tree Village Apartments. The conflict caused by this affair ultimately resulted in Appellant shooting and killing Stegall during a neighborhood Fourth of July celebration. At trial, Appellant admitted that he shot Stegall but claimed that he did so in self-defense. On appeal, Appellant argued the evidence was insufficient as a matter of constitutional and statutory law to disprove his claim of self-defense. Appellant also contended he received ineffective assistance of counsel because his trial counsel failed to effectively cross-examine a witness and failed to move for a mistrial when the trial evidence did not substantiate a factual claim made by the prosecutor in his opening statement. Appellant also asked that the Georgia Supreme Court consider the prejudicial effect of trial counsel’s errors cumulatively. Finding no reversible error, the Georgia Supreme Court affirmed. View "Maynor v. Georgia" on Justia Law

Javion Caldwell was charged with: felony murder predicated on aggravated assault (Count 1), felony murder predicated on possession of marijuana with intent to distribute (Count 2), aggravated assault (Count 3), and possession of marijuana with intent to distribute (Count 4). These charges arose in connection with the shooting death of Jaleen Harrell during a drug deal. Caldwell was found guilty of Counts 2 and 4 and not guilty of Counts 1 and 3. On appeal, Caldwell argued the trial court failed to charge the jury that it had to find that he shot Harrell with a handgun in order to find him guilty on Count 2. Caldwell alternatively argued that the jury’s verdicts on Counts 1, 2, and 3 were repugnant, because the jury’s verdicts on Counts 1 and 3 reflected a finding that he did not shoot Harrell, even as a party to the crime, which Caldwell argued also meant that it had to acquit him on Count 2. Finding no reversible error, the Georgia Supreme Court affirmed. View "Caldwell v. Georgia" on Justia Law

In 2020, Darnell Priester was convicted of malice murder, aggravated battery, and other crimes in connection with the shooting death of Thomas Robinson and the non-fatal shooting of Timothy Nelson. He appealed, arguing: (1) the evidence presented at trial was not sufficient to support them; (2) the trial court erred by denying him a new trial on the general grounds; and (3) the trial court committed plain error by not giving jury instructions related to justification and perjury. Priester also argued his trial counsel provided ineffective assistance by failing to object to the lack of jury instructions related to justification and perjury; failing to object to testimony that implicated Priester’s right to remain silent; failing to cross-examine Shane Godsey; requesting an instruction on the necessity of corroboration of accomplice testimony; failing to file a pretrial motion for immunity; and failing to object to narrative testimony, to “asked and answered” testimony, and to the prosecutor “testifying.” Finding no reversible error, the Georgia Supreme Court affirmed. View "Priester v. Georgia" on Justia Law

Antonio May died from injuries he sustained inside the Fulton County (Georgia) Jail while in the custody of the Fulton County Sheriff. The defendants, Aaron Cook, Jason Roache, Guito Dela Cruz, Omar Jackson, Kenesia Strowder, and William Whitaker, were employed as jailers by the Fulton County Sheriff and were on duty at the Jail when May died. The State alleged through indictments of the defendants for felony murder and other crimes the defendants beat, pepper sprayed, and repeatedly shocked May with an electronic taser, thereby causing his death. Claiming the pre-indictment protections afforded to “peace officers” under OCGA § 17-7-52, the defendants sought to quash their indictments on the basis that they did not receive preindictment notice and an opportunity to be heard. The trial court found that, while none of the defendants were empowered to make arrests, they were nevertheless charged with maintaining the public peace. To that end, the trial court reasoned that “within the community of over 3,000 inmates in the Fulton County Jail (which is accessible to the public in various controlled ways), detention officers are the maintainers of public order” in the event that “there is a fight in the mess hall over bad beans or a brawl in the common space over which channel the TV should be on[.]” On that basis, the trial court quashed the indictments. The State appealed. The Georgia Supreme Court concluded the trial court erred by finding that the defendants’ duty to control and supervise inmates within the jail constituted a duty to maintain the public peace. Accordingly, the judgments were reversed. View "Georgia v. Cook, et al." on Justia Law

Xavier Jones appealed his convictions for felony murder and other crimes in connection with the 2010 shooting death of Christopher Crumby. On appeal, Jones argued the trial court erred: (1) in not granting his motion for directed verdict at trial; (2) in not granting his motion for new trial on the general grounds; (3) by admitting a video recording of Jones’s interview in which Jones remained silent in response to some of the investigators’ questions and comments; (4) denying his motion for mistrial on that ground, and (5) by failing to meaningfully respond to a question submitted by the jury during deliberations. Jones also argued the evidence submitted at trial was insufficient to support his convictions. The Georgia Supreme Court vacated Jones' conviction for aggravated assault as it should have merged into his felony murder conviction. The Court affirmed Jones' convictions in all other respects. View "Jones v. Georgia" on Justia Law

Appellant Torry Bowman and his friend, Maurice Goodman, got into an argument in a bar with brothers Alec and Britian Price. They confronted the Price brothers again outside the bar, and Alec was shot and died as a result of his injuries. Bowman was convicted of malice murder and other crimes in connection with Alec’s death. On appeal, Bowman contended the trial court erred by: (1) instructing the jury on party to a crime, conspiracy, and provocation by words alone; and (2) failing to allow him to stipulate to his prior conviction to prove the required elements of Count 9 without stipulating that the conviction involved the possession or use of a firearm. He also argued that these errors, taken together, deprived him of a fair trial under Georgia v. Lane, 838 SE2d 808 (2020). Finding no reversible error, the Georgia Supreme Court affirmed. View "Bowman v. Georgia" on Justia Law

Appellant Torrey Kimbro was convicted of malice murder and rape in connection with the strangling death of Diamond Shepherd. On appeal, Kimbro contended the evidence presented at his trial was legally insufficient to support his convictions. He also claimed the trial court erred: by denying his motion for new trial on the “general grounds” set forth in OCGA §§ 5-5-20 and 5-5-21; by denying his motion for a continuance; by denying his motion to dismiss his indictment; by denying his motion for a mistrial; and by overruling his objections to certain statements that the prosecutor made during her closing argument. In addition, he claimed his trial counsel provided constitutionally ineffective assistance in several respects. Finding no reversible error, the Georgia Supreme Court affirmed. View "Kimbro v. Georgia" on Justia Law

Appellant Raekwon Pauldo was convicted of malice murder in connection with the 2017 shooting death of Jacquel Smith. On appeal, Pauldo contended his trial counsel provided constitutionally ineffective assistance by: (1) failing to adequately prepare the defense of accident; (2) failing to limit testimony concerning the registration of Pauldo’s gun; and (3) failing to adequately inform him of the State’s plea offer. Finding no reversible error, the Georgia Supreme Court affirmed. View "Pauldo v. Georgia" on Justia Law