Depriest v. State

907 S.E.2d 274, 319 Ga. 874
CourtSupreme Court of Georgia
DecidedOctober 1, 2024
DocketS24A1152
StatusPublished
Cited by1 cases

This text of 907 S.E.2d 274 (Depriest v. State) 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
Depriest v. State, 907 S.E.2d 274, 319 Ga. 874 (Ga. 2024).

Opinion

319 Ga. 874 FINAL COPY

S24A1152. DEPRIEST v. THE STATE.

BETHEL, Justice.

Darnell Cory Depriest was convicted of felony murder and

other crimes in connection with the shooting death of his cousin Ivan

Lovejoy Williams.1 On appeal, Depriest contends that the evidence

presented at trial was insufficient to support his conviction for

felony murder both as a matter of constitutional due process and

1 The crimes occurred on October 11, 2019. On January 3, 2020, a Newton

County grand jury indicted Depriest for malice murder (Count 1), felony murder (Counts 2 and 3), aggravated assault (Count 4), possession of a firearm during the commission of a felony (Counts 5 and 6), possession of a firearm by a convicted felon (Count 7), and cruelty to children in the third degree (Count 8). At a September 2021 jury trial, the jury found Depriest not guilty of malice murder, but guilty of all remaining counts. The trial court sentenced Depriest to serve life in prison on Count 2; five years in prison on Count 5, to run consecutively to Count 2; five years in prison on Count 7, to run concurrently with Count 2; and twelve months in prison on Count 8, to run concurrently with Count 2. Though the trial court purported to merge for sentencing purposes all the remaining counts, Count 3 was actually vacated by operation of law. See Noel v. State, 297 Ga. 698, 700 (2) (777 SE2d 449) (2015). Depriest filed a timely motion for new trial, which was later amended through new counsel. Following a hearing on May 24, 2023, the trial court denied the amended motion on January 30, 2024. Depriest then filed a timely notice of appeal, and his case was docketed to the August 2024 term of this Court and submitted for a decision on the briefs. under Georgia statutory law. He also argues that trial counsel

rendered ineffective assistance by failing to file a motion for

immunity from prosecution and that the trial court erred by denying

his request to charge the jury on defense of others. But the evidence

was sufficient to sustain Depriest’s conviction, trial counsel was not

deficient in failing to file a motion for immunity, and any error in

the trial court’s refusal to instruct the jury on defense of others was

harmless. So we affirm.

1. Viewed in the light most favorable to the verdicts, the

evidence presented at trial showed the following. Around midnight

on October 11, 2019, emergency personnel responded to a 911 call

regarding a shooting at Depriest’s residence. Upon arriving, officers

found Williams, who had been shot in the head, inside the residence.

Also at the scene were Depriest, Depriest’s sister Denise Williams,

and Depriest’s fiancée Tiffany Beatty. Denise and Beatty both

observed the events leading to Williams’s death and were

interviewed by officers at the crime scene; their interviews were

audio-recorded by an investigator and played for the jury at trial.

2 During her interview, Beatty stated that she was asleep in an

upstairs bedroom when she heard Depriest and Williams, who had

been drinking alcohol, arguing downstairs. Depriest then came into

Beatty’s bedroom “screaming” that Williams would not leave and

asked Beatty to talk to Williams. Beatty went downstairs, where

Williams explained that he would not leave because Depriest owed

him money. The men continued arguing, and Beatty positioned

herself between them. Beatty then saw that Depriest had a gun, and

she tried to convince him to give the gun to her. Depriest eventually

removed the magazine and handed the magazine to Beatty but “he

never put the gun down.” At some point, Williams “charged” toward

Beatty and Depriest, and the gun, which was still in Depriest’s hand

“went off.” Beatty explained that she had her back turned to

Depriest, who was behind her, when the gun went off.

For her part, Denise, who observed the confrontation from an

adjoining room, told investigators that Depriest and Williams began

arguing about money, with Williams claiming that Depriest owed

him $150. Depriest asked Williams to leave, but Williams refused,

3 and the two argued back and forth. After Williams “walked up on”

Depriest and pointed his finger at him, Depriest walked away and

returned with a gun. Depriest then went upstairs to get Beatty, who

came downstairs with Depriest and positioned herself between the

men, trying to break them up. When Depriest gave Beatty the

magazine from his gun, Beatty said to Denise, “I got the clip.” Then,

Williams “was like getting ready to charge” or “go into him to charge”

Depriest, and “the next thing [Denise] kn[e]w, the gun went off.”

Before the gunshot, Denise “saw [Depriest] aim the gun, then [she]

heard the gun go off, and [Williams] fell to the ground.” Beatty was

clear that she saw Depriest point the weapon at Williams before she

heard the gunshot.

The investigator then asked both women to describe the

physical positions of Depriest, Williams, and Beatty in the room. As

Denise described the scene, Depriest, Beatty, and Williams were

each some feet apart. The women agreed that only Depriest was

armed during the altercation. Testing showed that Beatty did not

have any blood on her clothes or person. A crime scene investigator

4 later testified that if someone were standing within a foot of

Williams, who was shot in the head, blood would very likely be found

on that person.

Depriest was arrested at the crime scene, and police also

recovered the gun used in the shooting. Later testing on the gun

revealed that the trigger-pull required approximately six-and-a-

quarter pounds of pressure, that the gun had a tendency not to fire

when the trigger was pulled, and that the gun misfired (i.e., did not

fire at all) on four of seven attempted shots.

Both Beatty and Denise later testified at trial. Both women

testified that Williams was unarmed at the time of the shooting, and

Beatty’s testimony was consistent with her interview at the crime

scene. Denise, however, recounted a somewhat different version of

events than what she told investigators on the night of the crimes.

Specifically, Denise testified that Williams, who was “angry” and

“very aggressive,” started walking over to Depriest “like he was

going to hurt him” as Depriest handed Beatty the magazine from his

gun. Denise testified that she saw Depriest and Beatty bend down

5 and, as they were standing back up, heard the gun go off; she then

saw Williams fall to the floor.

Depriest’s theory of defense at trial was that he accidentally

shot Williams or, alternatively, that he acted in self-defense after

Williams charged at him. Depriest did not testify. Neither did he call

any witnesses or seek to enter any other evidence for the defense.

2. In his first enumeration of error, Depriest contends that the

evidence presented at trial was insufficient both as a matter of

federal constitutional due process and under Georgia statutory law

to support his conviction for felony murder.2 We address these

arguments in turn.

(a) Depriest contends that the evidence at trial was insufficient

2 Depriest purports to challenge the sufficiency of the evidence as to all

seven counts of which he was found guilty.

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Bluebook (online)
907 S.E.2d 274, 319 Ga. 874, Counsel Stack Legal Research, https://law.counselstack.com/opinion/depriest-v-state-ga-2024.