DELOACH v. THE STATE (And Vice Versa)

308 Ga. 283
CourtSupreme Court of Georgia
DecidedFebruary 10, 2020
DocketS19A1299, S19X1300
StatusPublished
Cited by22 cases

This text of 308 Ga. 283 (DELOACH v. THE STATE (And Vice Versa)) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DELOACH v. THE STATE (And Vice Versa), 308 Ga. 283 (Ga. 2020).

Opinion

308 Ga. 283 FINAL COPY

S19A1299, S19X1300. DeLOACH v. THE STATE; and vice versa.

ELLINGTON, Justice.

A Chatham County jury found Arheem DeLoach guilty of two

counts of malice murder and other crimes in connection with the

deaths of Rashad Biggins and Jamell Law.1 In Case No. S19A1299,

1 On March 29, 2017, the State charged DeLoach and his co-defendant,

Tyrell Smith, with the malice murder of Biggins. DeLoach alone was charged with Law’s murder. The 18-count indictment also alleged felony murder, conspiracy to commit murder, aggravated assault, armed robbery, and weapons possession offenses. In August 2017, a Chatham County jury found DeLoach guilty on all counts, except those pertaining to armed robbery and those involving the aggravated assault of Carshai Murray, which had been nolle prossed on the morning of trial. The court sentenced DeLoach to serve consecutive life sentences for the malice murders and a five-year prison term for possession of a firearm during the commission of a felony to run concurrent with the second life sentence. The remaining counts either merged or were vacated by operation of law. DeLoach timely filed a motion for a new trial, which he later amended. On April 22, 2019, the trial court entered an order granting in part and denying in part DeLoach’s motion for a new trial. The order granted DeLoach a new trial as to all counts related to the death of Biggins; however, the order denied DeLoach a new trial on those crimes related to the death of Law. DeLoach filed a timely notice of appeal from the trial court’s order on April 23. On April 24, the State filed a notice of appeal from the same order, and this Court docketed the State’s appeal as a cross-appeal. The appeals were docketed to the August 2019 term and orally argued on September 11, 2019. DeLoach contends that the trial court erred in denying his motion

for a new trial with respect to the crimes committed against Law,

asserting that his trial counsel was ineffective in two ways: (1)

counsel failed to move to sever the counts involving Law from those

involving Biggins, and (2) counsel failed to object or to move for a

mistrial when the trial judge mentioned the appellate process before

giving the final jury charge. For the reasons set forth below in

Division 2, we disagree and affirm this portion of the trial court’s

judgment. In Case No. S19X1300, the State cross-appeals,

contending that the trial court erred in granting DeLoach a new trial

with respect to the crimes committed against Biggins.2 The State

argues that the trial court’s basis for granting a new trial — that the

prosecutor knowingly failed to correct material, false testimony from

a key witness — is unsupported by the record. As set forth in

Division 3, we reverse this portion of the trial court’s judgment

because the record does not support the trial court’s finding that the

2 Pursuant to OCGA § 5-7-1 (a) (8), the State may appeal from “an order,

decision, or judgment of a court granting a motion for new trial[.]” false testimony was material.

The facts relevant to both appeals are as follows. The State

prosecuted DeLoach for the April 26, 2015 murder of Biggins and

the June 20, 2015 murder of Law in the same trial on the theory that

the murders were revenge killings linked together by forensic

evidence and a witness to whom DeLoach admitted his involvement

in both crimes. Viewed in the light most favorable to the jury’s

verdicts, the record shows the following.

Around 9:30 p.m. on April 26, 2015, Biggins was shot to death

outside the Frazier Homes apartment complex in Savannah. He was

shot moments after leaving the apartment of his friend, Morgan

Suggs. Suggs testified that, as Biggins walked away, she heard a

series of gunshots, saw Biggins fall, and heard him scream: “It’s

burning. It hurts. It’s burning.” Suggs did not see the shooting, but

she saw two people running from where Biggins lay, one of whom

she knew and identified at trial as Tyrell Smith. Suggs testified that

she had seen Smith earlier that day when she and Biggins had been

outside the apartment, supervising a group of children that Suggs was babysitting. She said that Smith and a group of men, all of

whom were wearing red shirts, had arrived at the complex in

response to an argument involving the girlfriend of one of the men.

When the group arrived, Biggins and Suggs took the children inside.

Suggs testified that when she saw Smith later that evening, after

Biggins had been shot, Smith had changed out of his red shirt and

was then wearing all black.

When law enforcement responded to the shooting, Biggins was

still alive. He later died from his wounds at the hospital. He had

three gunshot wounds, one to his back, one to his right thigh, and

one to the sole of his foot. Investigators photographed the crime

scene, and gathered evidence of the shooting. They recovered seven

.40-caliber shell casings and four 9mm shell casings. The shell

casings were clustered together in two separate groups near

bloodstains not far from Suggs’ apartment, evidence from which a

detective inferred that there had been two gunmen. Images of the

shell casings were entered into a national database to be compared

with other shell-casing images to see if the images from the Biggins shooting matched those from other crime scenes.

Investigators obtained a warrant to search Smith’s apartment

on May 15, 2015. After removing an uncooperative Smith from his

apartment at gunpoint, investigators seized his cell phone. Smith’s

phone records revealed that he had sent a series of text messages

shortly after the shooting. At 12:07 a.m. on April 27, before

information about Biggins’ status had been released to the media,

Smith sent a message to “Mafioso” stating: “Mission failed Cuzz

bump me.” A few hours later, Smith texted “Mugg,” writing that,

although the “mission” had failed, the victim had been shot twice, in

the “back [and] side.” Then, after Biggins’ death was made public,

Smith sent a text to “John Da” stating: “187BMC.” The State

presented evidence that “187” is code for “homicide” and that “BMC”

stands for “Beast Mode Cousins.” Each of these outgoing texts

contained the signature line: “B.M.C. 4 LIFE R.I.P. MARVIN

HILLS.”

Forensic evidence gathered from the crime scene eventually led

the investigators to the second shooter, DeLoach. A forensic expert determined that the four 9mm shell casings from the Biggins

shooting matched a single 9mm shell casing recovered from the

scene of a shooting that had occurred on April 25, 2015, the day

before Biggins was killed. On April 25, DeLoach assaulted his ex-

girlfriend, Carshai Murray. Murray told the police that DeLoach

was jealous and believed that she had been unfaithful to him.

DeLoach, who was dressed all in black, surprised Murray by

jumping out from behind bushes by her home. He then fired a gun

at a car she was about to get into, and the driver of the car sped

away. DeLoach told Murray: “I could have got you.”3

On July 20, 2015, Jamell Law was shot to death with a .40-

caliber weapon while he sat in his car on Harden Street in

Savannah. Law had two passengers in the car with him. Before the

shooting, Law had been seen driving through the neighborhood,

looking for a friend.

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