The case concerns Henry Cook's appeal of a trial court ruling that he was not a resident of Randolph County and therefore not qualified to vote there, following a decision by the county Board of Registrars. Cook had challenged the registrars' determination under state election law, and the superior court upheld it after hearing evidence on his residency. The Supreme Court of Georgia determined it lacked jurisdiction because the matter was a voter qualification dispute not clearly tied to a specific election contest. Under the state constitution, the Court has exclusive appellate jurisdiction only over "cases of election contest," which this case did not qualify as, leading to a transfer to the Court of Appeals without addressing the merits.
The case involved Mario Westbrook's conviction for malice murder and related crimes after he shot and killed Stacey Jefferies and wounded others during a dice game, claiming self-defense. On appeal, Westbrook challenged the admission of a witness's prior statement under the rule of completeness and claimed ineffective assistance of counsel for not presenting evidence of victims' prior violent acts. The court affirmed the convictions, holding that the statement was properly admitted as relevant to rebut fabrication claims and address self-defense, any error was harmless given overwhelming evidence, and counsel was not ineffective because the additional evidence was not credible and unlikely to change the outcome.
The case concerned whether police officers' statements to a suspect that he could return home after questioning created a 'hope of benefit' under OCGA § 24-3-50 that would render his confession to child molestation inadmissible. The Georgia Supreme Court held that such statements do not make a confession involuntary unless they amount to a promise of no charges, reduced charges, or a reduced sentence. The officers told the 19-year-old suspect he would go home regardless of what he said (with an exception for killing someone), but made no promises about ultimate charging or sentencing decisions. After the suspect confessed, he was advised of his Miranda rights, waived them, and repeated his statements; the Court concluded these circumstances did not trigger the statutory prohibition and affirmed the Court of Appeals' reversal of the trial court's suppression order.
The case involved a personal injury lawsuit by Lisa Krebs against Carmen McReynolds and General Motors after McReynolds's car struck the GM vehicle in which Krebs was a passenger. After Krebs settled with GM, the trial court dismissed McReynolds's cross-claims against GM for contribution and set-off, and entered judgment against McReynolds for the full jury award of over $1.2 million. The Georgia Supreme Court affirmed, holding that OCGA § 51-12-33 mandates apportionment of damages among liable parties according to their percentages of fault even when the plaintiff bears no fault (eliminating joint liability and contribution), and that McReynolds's insurer had made a valid acceptance of the settlement demand rather than a counteroffer.
In Moore v. State, Calvin Moore was convicted of malice murder in the death of Lucius Harris, Jr., based on evidence that he lived with the victim, was seen striking him, threatened to kill him on the night of the murder, and was linked by physical evidence and witness accounts to the location where the victim's body was found on railroad tracks. The Georgia Supreme Court determined that the trial evidence was sufficient to support the jury's guilty verdict under the Jackson v. Virginia standard. However, the court held that the trial court erred by admitting similar transaction evidence regarding Moore's alleged involvement in a prior death without first conducting the hearing and making the on-the-record findings required by Uniform Superior Court Rule 31.3(B). The judgment was therefore vacated and the case remanded for a proper Rule 31.3 hearing or, if necessary, a new trial.
In 1999, Demetric Andre Smith was convicted in Fulton County of felony murder and cruelty to a child for stabbing his girlfriend to death and was sentenced to life plus twenty years; this Court affirmed the convictions on direct appeal. More than ten years later, Smith filed a pro se motion in arrest of judgment, which the trial court denied on the merits without a hearing. The Supreme Court affirmed, holding that the motion was untimely under OCGA § 17-9-61(b) because it was not filed during the term of court when the judgment was entered and that precedent requires affirmance of the denial of such untimely motions rather than reaching the merits.
