Jatony Dupree v. State

CourtCourt of Appeals of Georgia
DecidedFebruary 20, 2025
DocketA24A1736
StatusPublished

This text of Jatony Dupree v. State (Jatony Dupree v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jatony Dupree v. State, (Ga. Ct. App. 2025).

Opinion

FIFTH DIVISION MERCIER, C. J., MCFADDEN, P. J., and RICKMAN, P. J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

February 20, 2025

In the Court of Appeals of Georgia A24A1736. DUPREE v. THE STATE.

MCFADDEN, Presiding Judge.

After a jury trial, Jatony Dupree was convicted of exploitation and intimidation

of a disabled adult (OCGA § 16-5-102 (a)); aggravated assault (OCGA § 16-5-21);

violation of the Georgia Street Gang Terrorism and Prevention Act (OCGA § 16-15-1

et. seq); and false imprisonment (OCGA § 16-5-41). The trial court denied his motion

for new trial, and he filed this timely appeal.

Dupree argues that the evidence was insufficient to support the conviction of

exploitation and intimidation of a disabled adult because the state failed to prove that

the victim was disabled. We agree. The state failed to present evidence that any

impairment the victim may have had substantially affected his abilities, as the statutes establishing this crime require to prove the victim is disabled. So we reverse that

conviction.

Dupree argues that the trial court erred by failing to instruct the jury on battery

as a lesser included offense of aggravated assault. Under the evidence presented at the

trial of this case, we agree. So we vacate that conviction. But because the evidence

presented at trial was legally sufficient to authorize a rational jury to find Dupree

guilty beyond a reasonable doubt of aggravated assault, Dupree may be retried on the

aggravated assault counts of the indictment.

Dupree argues that the evidence was insufficient to support his conviction for

violation of the Georgia Street Gang Terrorism and Prevention Act. We hold that the

state presented sufficient evidence from which a rational jury could find beyond a

reasonable doubt that Dupree violated the Act. So we affirm that conviction.

Dupree argues that the trial court erred by failing to sua sponte declare a

mistrial when the members of the jury expressed concern about the foreperson’s name

being made public and that the trial court erred by sealing the verdict in answer to the

jurors’ concern. Dupree has not shown reversible error.

2 Dupree raises several arguments regarding the admission of evidence. He has

not shown reversible error for any of them. Finally, Dupree argues that trial counsel

was ineffective. We hold that he has failed to show both deficient performance and

prejudice.

In sum, we reverse the conviction for exploitation and intimidation of a disabled

adult. We vacate the conviction for aggravated assault, although Dupree may be

retried on that charge. We affirm the conviction for violation of the Georgia Street

Gang Terrorism Act and the conviction for false imprisonment.

1. Evidence at trial

The evidence presented at trial1 showed that the victim was at his aunt’s

apartment, when Joel Denson, a member of the Gangster Disciples gang, entered the

apartment and began speaking with the aunt. Denson then questioned the victim about

the victim’s claim that he was a member of the gang. The victim had adopted the

language of the gang while he was in prison and had been telling people that he was a

1 “In light of the harmless-error analysis we undertake [elsewhere in] this opinion, we review the record de novo, and we weigh the evidence as we would expect reasonable jurors to have done so as opposed to viewing it all in the light most favorable to the jury’s verdict.” Moore v. State, 315 Ga. 263, 264 (1) n.2 (882 SE2d 227) (2022). 3 member of the gang. The members of the Gangster Disciples punish people for falsely

claiming to be a member of the gang.

Denson made a telephone call, and 15 to 20 minutes later, a group of four men,

including Dupree, came to the apartment. The men held down the victim and began

beating him. Denson instructed the men to “[b]ust his ribs up.” In the video, one of

the assailants exclaimed, “ you claiming G. D.” “G. D.” is shorthand for “Gangster

Disciples.”

During the assault, the victim said that he is “6-0-6” or “F-O-F,” terminology

that at one time meant “friend of the gang.” One of the men beating the victim

responded, “6-0-6 don’t mean nothing around here[.]” An assailant filmed the

incident, and the video recording was played for the jury. The state introduced

photographs showing the victim’s broken ribs.

An expert in gangs generally and the Gangster Disciples in particular testified

that the Gangster Disciples have a presence in Dublin, Georgia, where this incident

occurred. According to the expert, the members of the gang are “fiercely loyal” to

their brand and protect it by preventing people who are not members from claiming

that they are. The expert testified that the Gangster Disciples have a rule that requires

4 them to respond if another member calls for assistance, so the group of men coming

to the apartment after Denson’s phone call was consistent with Gangster Disciples

culture.

2. Exploitation and intidmidation of a disabled adult

Dupree argues that the evidence did not support his conviction for exploitation

and intimidation of a disabled adult because the state did not prove that the victim was

disabled. We agree.

OCGA § 16-5-102 (a) provides, “Any person who . . . willfully inflicts physical

pain [or] physical injury . . . upon a disabled adult . . . shall be guilty of a felony . . . .”

OCGA § 16-5-100 (3) defines “disabled adult” to mean “a person 18 years of age or

older who is mentally or physically incapacitated. . . .” OCGA § 16-5-100 (7.1), in

turn, defines “mentally or physically incapacitated” to mean “an impairment which

substantially affects an individual’s ability to . . . [p]rovide personal protection; . . .

[p]rovide necessities, including but not limited to food, shelter, clothing, medical, or

other health care; . . . [c]arry out the activities of daily living; or . . . [m]anage his or

her resources.”

5 Viewed in the light most favorable to the verdict, Rooks v. State, 317 Ga. 743, 751

(2) (893 SE2d 899) (2023), the record shows that the state presented evidence that the

victim has a mental illness and an intellectual disability; that he has a mental health

counselor; that he completed the ninth grade; and that he was in special needs classes

while he was in school. But the state presented no evidence that any impairment

substantially affected his ability to provide personal protection, to provide necessities,

to carry out the activities of daily living, or to manage his resources.

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