Georgia Case Commentaries

Bodie v. State: No Plain-Error Relief for Omitted, Unrequested Accident Charge Where Self-Defense Was the Strategic Theory and Prejudice Is Not Shown

Date: Mar 19, 2026

Bodie v. State: No Plain-Error Relief for Omitted, Unrequested Accident Charge Where Self-Defense Was the Strategic Theory and Prejudice Is Not Shown 1. Introduction In Bodie v. The State (Supreme...

Bustamente v. State: Lack-of-Remorse Sentencing Factor Must Be Grounded in Trial Record, Not Punishment for Sentencing Silence

Date: Mar 19, 2026

Lack-of-Remorse Sentencing Factor Must Be Grounded in Trial Record, Not Punishment for Sentencing Silence (Bustamente v. State) 1. Introduction In Bustamente v. The State (Supreme Court of Georgia,...

Reasonable Strategic Non-Objection to Closing-Argument Remarks Bars Ineffective-Assistance Relief

Date: Mar 19, 2026

Reasonable Strategic Non-Objection to Closing-Argument Remarks Bars Ineffective-Assistance Relief 1. Introduction In Fadesire v. The State (Supreme Court of Georgia, Mar. 17, 2026), Faruk Adedapo...

Badie v. State: Co-Defendant’s Post-Trial Plea Does Not Affect Party-to-the-Crime Murder Liability; Bruton Limits and Plain-Error Harm for Missing Limiting Instruction

Date: Mar 19, 2026

Badie v. State: Co-Defendant’s Post-Trial Plea Does Not Affect Party-to-the-Crime Murder Liability; Bruton Limits and Plain-Error Harm for Missing Limiting Instruction Court: Supreme Court of Georgia...

Dill v. State: Brief Juror–Witness Hallway Contact Held “Inconsequential,” Presumption of Prejudice Rebutted Beyond a Reasonable Doubt

Date: Mar 19, 2026

Dill v. State: Brief Juror–Witness Hallway Contact Held “Inconsequential,” Presumption of Prejudice Rebutted Beyond a Reasonable Doubt Supreme Court of Georgia — Decided March 17, 2026 (S26A0125) 1....

Hernandez v. State: No Ineffective Assistance for Failing to Object to Permissible Closing Argument (Truth-Plea References, Illustrative Analogies, “Common Sense” Reasonable Doubt, and “Send a Message” Rebuttal)

Date: Mar 19, 2026

Hernandez v. State: No Ineffective Assistance for Failing to Object to Permissible Closing Argument (Truth-Plea References, Illustrative Analogies, “Common Sense” Reasonable Doubt, and “Send a...

Disbarment for Knowing Conversion of Client Funds and Pattern Neglect Despite Mental-Health Mitigation — In the Matter of Charles Bruce Singleton, Jr.

Date: Mar 19, 2026

Disbarment for Knowing Conversion of Client Funds and Pattern Neglect Despite Mental-Health Mitigation Case: In the Matter of Charles Bruce Singleton, Jr. (S26Y0233) — Court: Supreme Court of Georgia...

Discredited Defendant Testimony Alone Cannot Prove Plea-Deal Prejudice Under Strickland/Lafler

Date: Mar 19, 2026

Discredited Defendant Testimony Alone Cannot Prove Plea-Deal Prejudice Under Strickland/Lafler 1. Introduction Jackson v. State (Supreme Court of Georgia, decided March 17, 2026) addresses a...

Jackson v. State: Disruptive Conduct Can Forfeit a Defendant’s Rights to Be Present and to Testify

Date: Mar 19, 2026

Jackson v. State: Disruptive Conduct Can Forfeit a Defendant’s Rights to Be Present and to Testify 1. Introduction In Jackson v. The State (Supreme Court of Georgia, March 17, 2026), Devon Jackson...

Patterson v. State (Ga. 2026): Ineffective-Assistance Claims Are Waived If Not Raised in the Motion for New Trial When New Counsel Is Appointed

Date: Mar 19, 2026

Patterson v. State (Ga. 2026): Ineffective-Assistance Claims Are Waived If Not Raised in the Motion for New Trial When New Counsel Is Appointed Court: Supreme Court of Georgia Date: March 17, 2026...

Co-Resident Lacks “Authority” to Enter Another Tenant’s Rented Bedroom for OCGA § 16-7-5(b) Home Invasion

Date: Mar 19, 2026

Co-Resident Lacks “Authority” to Enter Another Tenant’s Rented Bedroom for OCGA § 16-7-5(b) Home Invasion Introduction In Rainey v. State (Supreme Court of Georgia, decided March 17, 2026), Shadreen...

Failure to Object Does Not Waive an Ineligible-Juror Claim Absent Knowledge or Discoverability by Ordinary Diligence (Simms v. State)

Date: Mar 19, 2026

Failure to Object Does Not Waive an Ineligible-Juror Claim Absent Knowledge or Discoverability by Ordinary Diligence Case: Simms v. The State Court: Supreme Court of Georgia Date: March 17, 2026...

Williams v. State: Speculative Prejudice Is Insufficient to Overturn Denial of Continuance; Unpreserved Prosecutorial Misconduct Is Not Plain-Error Reviewable

Date: Mar 19, 2026

Williams v. State: Speculative Prejudice Is Insufficient to Overturn Denial of Continuance; Unpreserved Prosecutorial Misconduct Is Not Plain-Error Reviewable Introduction In Williams v. The State...

RPA Immunity Extends to City Sidewalks Used for Sightseeing in Historic Districts; “Recreational Use” Assessed Objectively

Date: Mar 19, 2026

RPA Immunity Extends to City Sidewalks Used for Sightseeing in Historic Districts; “Recreational Use” Assessed Objectively 1. Introduction In THE MAYOR AND ALDERMEN OF THE CITY OF SAVANNAH v. McLAMB...

OCGA § 32-4-93(a) Limits Road-Defect Liability but Does Not Waive Municipal Immunity; OCGA § 36-33-1(b) Waiver Applies Only to Ministerial Street-Safety Duties Within Lanes of Ordinary Travel

Date: Mar 14, 2026

OCGA § 32-4-93(a) Limits Road-Defect Liability but Does Not Waive Municipal Immunity; OCGA § 36-33-1(b) Waiver Applies Only to Ministerial Street-Safety Duties Within Lanes of Ordinary Travel 1....

Confrontation Clause Requires Separate “Testimonial” Showing (Not Just Hearsay): Watkins v. State Partially Overruled After Smith v. Arizona

Date: Mar 14, 2026

Confrontation Clause Requires Separate “Testimonial” Showing (Not Just Hearsay): Watkins v. State Partially Overruled After Smith v. Arizona Supreme Court of Georgia — Decided March 12, 2026 —...

Untimely OCGA § 16-3-24.2 Immunity Motions: Trial-Court Discretion to Decline Consideration Once the OCGA § 17-7-110 Deadline Has Lapsed

Date: Mar 7, 2026

Untimely OCGA § 16-3-24.2 Immunity Motions: Trial-Court Discretion to Decline Consideration Once the OCGA § 17-7-110 Deadline Has Lapsed Introduction Mitchell v. State (Supreme Court of Georgia,...

Senior v. State: No Strickland Prejudice from Unused Felony-Impeachment Where Independent Eyewitness Evidence and Defense Theory Dilute Credibility Value

Date: Mar 7, 2026

No Strickland Prejudice from Unused Felony-Impeachment Where Independent Eyewitness Evidence and Defense Theory Dilute Credibility Value Introduction In Senior v. The State (Supreme Court of Georgia,...

Strong v. State (Ga. 2026) Commentary

Date: Mar 7, 2026

Unstricken Answer Is Evidence: A Prosecutor May Argue a Defendant’s Refusal to Demonstrate When the Refusal Was Heard by the Jury and Not Stricken Case: Strong v. State, S25A1107 (Supreme Court of...

Woods v. State: Deliberation-Schedule Guidance to Deadlocked Juries Is Not Coercion; Any Rule 404(b) Error Is Harmless Where Guilt Evidence Is Strong and Limited by Instructions

Date: Mar 7, 2026

Woods v. State: Deliberation-Schedule Guidance to Deadlocked Juries Is Not Coercion; Any Rule 404(b) Error Is Harmless Where Guilt Evidence Is Strong and Limited by Instructions Introduction In Woods...

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