Georgia Case Commentaries

Williams v. State (2025): Preservation of Ineffective-Assistance Claims and the Prejudice Prong Clarified

Date: Aug 14, 2025

Williams v. State (2025): Preservation of Ineffective-Assistance Claims and the Prejudice Prong Clarified Introduction On 12 August 2025, the Supreme Court of Georgia delivered its decision in...

“A Six-Month Benchmark for Accounting Violations & Fitness-to-Practice Condition” – Commentary on In the Matter of Charles M. Dalziel, Jr.

Date: Jul 23, 2025

“A Six-Month Benchmark for Accounting Violations & Fitness-to-Practice Condition” Commentary on In the Matter of Charles M. Dalziel, Jr. 1. Introduction In In the Matter of Charles M. Dalziel, Jr....

In re Chin: Georgia Supreme Court Re-Aligns Disciplinary Sanctions for Knowing Misappropriation and Client-Injury

Date: Jul 23, 2025

In re Chin: Georgia Supreme Court Re-Aligns Disciplinary Sanctions for Knowing Misappropriation and Client-Injury Introduction In In the Matter of Justin Allen Chin (S25Y0879, decided 22 July 2025)...

Adams v. State: Georgia Supreme Court Re-Enforces the Edge Limits—Felon-in-Possession Felony-Murder Stands Outside the Modified Merger Rule and Sets Fresh Guidance on Plain-Error Review

Date: Jul 3, 2025

Adams v. State: Georgia Supreme Court Re-Enforces the Edge Limits—Felon-in-Possession Felony-Murder Stands Outside the Modified Merger Rule and Sets Fresh Guidance on Plain-Error Review 1....

Chapman v. State (2025): Clarifying Judicial Commentary under OCGA § 17-8-57 and Witness-Based Authentication of Firearm Evidence

Date: Jul 3, 2025

Chapman v. State (2025): Clarifying Judicial Commentary under OCGA § 17-8-57 and Witness-Based Authentication of Firearm Evidence 1. Introduction In Chapman v. The State and its companion case Watson...

Clarifying Waiver of the Defendant’s Right to be Present During Jury Viewings: A Commentary on Jacobs v. State (Ga. 2025)

Date: Jul 3, 2025

Clarifying Waiver of the Defendant’s Right to be Present During Jury Viewings: A Commentary on Jacobs v. State (Supreme Court of Georgia, 2025) Case: Jacobs v. State, S25A0570, Supreme Court of...

Kitchens v. State: Georgia High Court Demands Precise Fact-Finding and Distinct Barker–Doggett Analysis in Speedy-Trial Claims

Date: Jul 3, 2025

Kitchens v. State: Georgia High Court Demands Precise Fact-Finding and Distinct Barker–Doggett Analysis in Speedy-Trial Claims Introduction On 1 July 2025, the Supreme Court of Georgia delivered a...

The “Infliction Rule”: Georgia Supreme Court Clarifies Venue in Felony-Murder Prosecutions – Commentary on Lewis v. State (2025)

Date: Jun 30, 2025

The “Infliction Rule”: Georgia Supreme Court Clarifies Venue in Felony-Murder Prosecutions A Comprehensive Commentary on Lewis v. State, S25A0023 (Ga. June 26 2025) Introduction Aaron Lewis was...

City of Milton v. Chang: Georgia Re-defines “Road” to Include the Shoulder, Expanding Municipal Liability and Clarifying Pre-Judgment Interest

Date: Jun 30, 2025

City of Milton v. Chang: Georgia Re-defines “Road” to Include the Shoulder, Expanding Municipal Liability and Clarifying Pre-Judgment Interest Introduction On 24 June 2025 the Supreme Court of...

“Plain-Error Limits on Flight Instructions & Party Liability Proof” – A Commentary on Arnsdorff v. State (Ga. 2025)

Date: Jun 30, 2025

“Plain-Error Limits on Flight Instructions & Party Liability Proof” A Structured Commentary on Arnsdorff v. State, Supreme Court of Georgia, 24 June 2025 I. Introduction On 24 June 2025 the Supreme...

“Slight but Sufficient” — Bowdery v. State and the Modern Standard for Corroborating Accomplice Testimony in Georgia

Date: Jun 30, 2025

“Slight but Sufficient” — Bowdery v. State and the Modern Standard for Corroborating Accomplice Testimony in Georgia Introduction Bowdery v. State, Supreme Court of Georgia, decided 24 June 2025, is...

Coleman v. State: One Proceeding, One Penalty – Georgia Supreme Court Clarifies Scope of Criminal Contempt and Fifth-Amendment Protection

Date: Jun 30, 2025

Coleman v. State: One Proceeding, One Penalty – Georgia Supreme Court Clarifies Scope of Criminal Contempt and Fifth-Amendment Protection Introduction On 24 June 2025, the Supreme Court of Georgia...

Service to the Office, Not the Individual: Fleureme v. City of Atlanta and the Flexible Interpretation of OCGA § 36-33-5(f)

Date: Jun 30, 2025

Service to the Office, Not the Individual: Fleureme v. City of Atlanta and the Flexible Interpretation of OCGA § 36-33-5(f) Introduction On 24 June 2025 the Supreme Court of Georgia delivered a...

Foots v. State: Strengthening the Jury’s Power to Convert Disbelieved Self-Defense Testimony into Substantive Evidence of Guilt

Date: Jun 30, 2025

Foots v. State: Strengthening the Jury’s Power to Convert Disbelieved Self-Defense Testimony into Substantive Evidence of Guilt Introduction In Foots v. State, S25A0646 (Ga. June 24 2025), the...

The Fuller Doctrine: Reconciling Constitutional Sufficiency with Georgia’s Circumstantial-Evidence Statute in Party-to-Crime Convictions

Date: Jun 30, 2025

The Fuller Doctrine: Reconciling Constitutional Sufficiency with Georgia’s Circumstantial-Evidence Statute in Party-to-Crime Convictions Introduction Fuller v. State, decided by the Supreme Court of...

“Plea-Bound but Not Fixed”: Gayle v. State and the Expanded Discretion of Georgia Juries to Treat Guilty-Plea Witnesses as Non-Accomplices

Date: Jun 30, 2025

“Plea-Bound but Not Fixed”: Gayle v. State and the Expanded Discretion of Georgia Juries to Treat Guilty-Pleas as Non-Accomplice Testimony Introduction On 24 June 2025, the Supreme Court of Georgia...

Reframing Municipal Instrumentality Sovereign Immunity: Guy v. Housing Authority of Augusta and the Common-Law Mandate

Date: Jun 30, 2025

Reframing Municipal Instrumentality Sovereign Immunity: Guy v. Housing Authority of the City of Augusta, 312 Ga. ___ (2025) Introduction The Supreme Court of Georgia’s decision in Guy v. Housing...

Hart v. State – 2025: Supreme Court of Georgia Re-anchors Appellate Jurisdiction in Non-Capital Murder Appeals on its Certiorari Power

Date: Jun 30, 2025

Hart v. State – 2025: Supreme Court of Georgia Re-anchors Appellate Jurisdiction in Non-Capital Murder Appeals on its Certiorari Power Introduction In Hart v. State the Supreme Court of Georgia...

The “Crime-Spree Joinder” Doctrine & Harmless Rule 404(b) Error: A Commentary on Lee v. State (Ga. 2025)

Date: Jun 30, 2025

The “Crime-Spree Joinder” Doctrine & Harmless Rule 404(b) Error: A Commentary on Lee v. State, 321 Ga. 87 (2025) Introduction In Lee v. State, the Supreme Court of Georgia faced an appeal arising...

No Proffer, No Prejudice: The Padgett Clarification on Ineffective-Assistance Claims in Georgia

Date: Jun 30, 2025

No Proffer, No Prejudice: The Padgett Clarification on Ineffective-Assistance Claims in Georgia Introduction Padgett v. State, S25A0719 (Ga. June 24, 2025), presented the Supreme Court of Georgia...