Georgia Case Commentaries

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...

“Quintanar v. State”: Georgia Supreme Court Re-anchors Juvenile Confession Analysis on “Coercive-Police-Activity” and Clarifies Limits on Self-Defense & Mutual-Combat Charges

Date: Jun 30, 2025

“Quintanar v. State”: Georgia Supreme Court Re-anchors Juvenile Confession Analysis on “Coercive-Police-Activity” and Clarifies Limits on Self-Defense & Mutual-Combat Charges I. Introduction...

Turner v. MCCG: Re-defining the Reach of Nestlehutt and Requiring Claim-Specific Analysis of Georgia’s Medical Malpractice Damage Caps

Date: Jun 30, 2025

Turner v. MCCG: Re-defining the Reach of Nestlehutt and Requiring Claim-Specific Analysis of Georgia’s Medical Malpractice Damage Caps Introduction In The Medical Center of Central Georgia, Inc. v....

“A Trivial Sum, Not a Treasure Chest” – Georgia Supreme Court Re-defines the Ceiling on Nominal Damages in Walmart Stores East, LP v. Leverette

Date: Jun 30, 2025

“A Trivial Sum, Not a Treasure Chest” – Georgia Supreme Court Re-defines the Ceiling on Nominal Damages in Walmart Stores East, LP v. Leverette Introduction On 24 June 2025, the Supreme Court of...

Wilson v. State: Georgia Supreme Court Narrows “Common Plan or Scheme” under Rule 404(b) and Clarifies Harmless-Error Review

Date: Jun 30, 2025

Wilson v. State: Georgia Supreme Court Narrows “Common Plan or Scheme” under Rule 404(b) and Clarifies Harmless-Error Review 1. Introduction Citation: Wilson v. State, S25A0430, Supreme Court of...

Reaffirming the “Any-Particular” Corroboration Standard & Harmless-Error Review of Rule 404(b) Evidence: Commentary on Boone v. State (Ga. 2025)

Date: Jun 11, 2025

Reaffirming the “Any-Particular” Corroboration Standard & Harmless-Error Review of Rule 404(b) Evidence: Commentary on Boone v. State (Supreme Court of Georgia, 2025) 1. Introduction On 10 June 2025...

Clark v. State: Judicial Discretion to Validate Timely Pro Se Notices of Appeal Filed While Counsel of Record Remains

Date: Jun 11, 2025

Clark v. State: Judicial Discretion to Validate Timely Pro Se Notices of Appeal Filed While Counsel of Record Remains Introduction Clark v. State, decided by the Supreme Court of Georgia on 10 June...

Coston v. State: Surveillance Video as Direct Evidence and the Limited Reach of Georgia’s Circumstantial-Evidence Rule

Date: Jun 11, 2025

Coston v. State: Surveillance Video as Direct Evidence and the Limited Reach of Georgia’s Circumstantial-Evidence Rule Introduction On 10 June 2025 the Supreme Court of Georgia decided Coston v....

“No Toll for Minors”: The Supreme Court of Georgia Declares OCGA § 9-3-90(b) Inapplicable to Municipal Ante Litem Notices in Dates v. City of Atlanta

Date: Jun 11, 2025

“No Toll for Minors”: The Supreme Court of Georgia Declares OCGA § 9-3-90(b) Inapplicable to Municipal Ante Litem Notices in Dates v. City of Atlanta 1. Introduction In Dates v. City of Atlanta,...

“Direct Evidence Prevails & Assault-Merger Mandate” — Comment on Douglas v. State (Supreme Court of Georgia, 2025)

Date: Jun 11, 2025

“Direct Evidence Prevails & Assault-Merger Mandate” A Comprehensive Commentary on Douglas v. State, 315 Ga. ___ (2025) 1. Introduction On 10 June 2025 the Supreme Court of Georgia decided Douglas v....

Floyd v. State: Reinforcing Circumstantial-Evidence Sufficiency for Predicate Armed Robbery and Delineating Confrontation Clause Limits when a Co-Indictee Refuses to Testify

Date: Jun 11, 2025

Floyd v. State: Reinforcing Circumstantial-Evidence Sufficiency for Predicate Armed Robbery and Delineating Confrontation Clause Limits when a Co-Indictee Refuses to Testify Introduction Floyd v....

James v. State: Confrontation Clause Does Not Extend to a Defendant’s Own Witness Invoking the Fifth Amendment

Date: Jun 11, 2025

James v. State: Confrontation Clause Does Not Extend to a Defendant’s Own Witness Invoking the Fifth Amendment Introduction In James v. State, the Supreme Court of Georgia confronted two familiar...

Lewis v. State: The Supreme Court of Georgia Re-Affirms Jury Primacy in Self-Defense Determinations and Clarifies Abandonment of Unbriefed Ineffective-Assistance Claims

Date: Jun 11, 2025

Lewis v. State: The Supreme Court of Georgia Re-Affirms Jury Primacy in Self-Defense Determinations and Clarifies Abandonment of Unbriefed Ineffective-Assistance Claims Introduction In Lewis v. State...

“Back to First Principles” – The Georgia Supreme Court Re-Inscribes a Strict Non-Delegation Rule and Rejects Federal-Style Third-Party Standing

Date: Jun 11, 2025

“Back to First Principles” – The Georgia Supreme Court Re-Inscribes a Strict Non-Delegation Rule and Rejects Federal-Style Third-Party Standing 1. Introduction The consolidated appeals Republican...

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