Mayo v. State

319 Ga. 34
CourtSupreme Court of Georgia
DecidedMay 14, 2024
DocketS24A0094
StatusPublished
Cited by1 cases

This text of 319 Ga. 34 (Mayo 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
Mayo v. State, 319 Ga. 34 (Ga. 2024).

Opinion

319 Ga. 34 FINAL COPY

S24A0094. MAYO v. THE STATE.

COLVIN, Justice.

Appellant Justin Scott Mayo appeals his convictions for malice

murder and other crimes related to the beating death of his

girlfriend, Stephanie Smith.1 Appellant argues that the trial court

1 Smith died on November 4, 2017. On December 19, 2017, a White County grand jury indicted Appellant for one count of malice murder (Count 1), one count of felony murder (Count 2) predicated on a count of aggravated assault (Count 3), and an additional two counts of felony murder (Counts 4 and 6), each of which was predicated on a separate count of aggravated battery (Counts 5 and 7). Appellant was tried by a jury from March 2 to March 6, 2020. Following the close of the State’s evidence, the trial court granted Appellant’s motion for directed verdict as to Counts 4 through 7, thereby acquitting Appellant of two counts of felony murder and the two counts of aggravated battery on which those felony murder counts were predicated. On March 6, 2020, the jury found Appellant guilty of all the remaining counts: malice murder (Count 1), felony murder (Count 2), and aggravated assault (Count 3). On March 10, 2020, Appellant was sentenced to life in prison without the possibility of parole for malice murder (Count 1). Though the trial court purported to merge Counts 2 and 3 into Count 1, Count 2 was actually vacated by operation of law. See Williams v. State, 316 Ga. 147, 153 (3) (886 SE2d 818) (2023). On April 1, 2020, Appellant filed a timely motion for new trial, which he subsequently amended through new counsel on August 10, 2020, and again on October 25, 2022. Because Appellant’s motion for new trial concerned the trial judge’s ex parte communication with the jury, Appellant filed a motion to recuse on April 17, 2020, which Appellant supplemented with an additional filing on the same day. Appellant’s motion to recuse was granted on May 9, committed two reversible errors: (1) the trial court presented the

jury with a “confusing” verdict form that was inconsistent with the

jury charge; and (2) the trial court received and responded to a note

from the jury during its deliberations without informing the parties,

thereby depriving Appellant of his right to be present throughout

the proceedings against him under Article I, Section I, Paragraph

XII of the Georgia Constitution and his right to effective assistance

of counsel under the Sixth Amendment to the United States

Constitution.2 For the reasons stated below, Appellant’s claims fail.

2022, and a different judge was appointed to hear Appellant’s motion for new trial. Following the subsequent judge’s appointment, the trial court held a hearing on Appellant’s motion for new trial on November 22, 2022, and denied it by written order on January 27, 2023. On February 24, 2023, Appellant filed a timely notice of appeal directed to this Court. The case was assigned to the term of this Court beginning in December 2023 and decided on the briefs. 2 Appellant never states expressly whether his claims arise under the

United States Constitution or the Georgia Constitution. Though he does not cite either constitution, Appellant avers in his brief that he “raised both the state and federal constitutional violations of Lowery [v. State, 282 Ga. 68 (646 SE2d 67) (2007)] and the failure to follow this Court’s Lowery procedures” during the hearing on his motion for new trial. Lowery concerned a defendant’s right to be present at trial under the Georgia Constitution and his right to counsel under the Sixth Amendment to the United States Constitution. See Lowery, 282 Ga. at 73 (4) (b). Appellant also cites Carter v. State, 273 Ga. 428 (541 SE2d 366) (2001) and Hanifa v. State, 269 Ga. 797 (505 SE2d 731) (1998), each of which concerns a defendant’s right to be present at trial under Article I, Section I, Paragraph XII of the Georgia Constitution. See Carter, 273 Ga. at

2 1. At approximately 2:00 p.m. on November 4, 2017, Appellant

entered the White County Sheriff’s Office and told the detention

officer at the front desk that he thought his girlfriend, Smith, was

dead. Law enforcement officers were dispatched to Appellant and

Smith’s shared residence, where they found a trail of bloodstains

from Smith’s car in the driveway, along the front porch, to the door,

which had been kicked in. Inside, Smith was found deceased, lying

nude in her bed, covered by a blanket and a small red towel or

washcloth over her eyes. Her body exhibited numerous and

extensive injuries, and the bedroom itself was littered with broken

and overturned objects. There appeared to be bloodstains on the

floor, and there were large amounts of dried blood in the nearby

bathroom.

429-430 (3); Hanifa, 269 Ga. at 807 (6). We therefore conclude that Appellant’s challenge to the trial court’s alleged infringement of his right to be present concerns Appellant’s right under the Georgia Constitution and that his claim regarding effective assistance of counsel is raised under the United States Constitution. We remind counsel to cite those portions of the constitutions on which they rely. See Supreme Court Rule 19 (1) (g) (requiring the appellant’s brief to contain an argument section which “cite[s] the authorities relied on”); Supreme Court Rule 22 (2) (“[B]riefs must contain full and complete citations of authority.”). 3 While law enforcement officers were searching Appellant’s

home, Appellant remained at the White County Sheriff’s Office.

There, he gave one written statement and two oral statements to

law enforcement officers. Appellant’s second oral statement was

video-recorded, admitted into evidence at trial, and played for the

jury. In Appellant’s second oral statement, which was consistent

with his first, Appellant explained that he and Smith had gone out

the prior evening with Smith’s friends to two bars in Helen, Georgia.

Appellant stated that he “black[ed] out” from alcohol, but that he

partially remembered getting into a verbal fight with Smith in

Helen because she had been flirting with and “touching” another

man at one of the bars. Appellant further stated that he did not

remember whether he or Smith drove them home, but that he had

some memory of getting into a physical fight with Smith during the

drive, kicking in the front door, and continuing the altercation before

and after Smith took a bath. Though Appellant’s reported memory

of the events was incomplete, he admitted that he was the sole

person responsible for Smith’s death.

4 A subsequent autopsy revealed the extent of Smith’s injuries.

According to the testimony of Dr. John Wassum, an assistant

medical examiner for the GBI, Smith had dozens of contusions

across the front and sides of her body consistent with blunt-force

trauma. There were at least ten contusions on her face, covering

both cheeks and both eyes, her forehead, chin, jawline, and earlobe.

Further injuries consistent with blunt-force trauma were found on

her abdomen, chest, arms, and hands, as well as on her knees, shins,

and both ankles. An internal examination revealed that Smith had

two broken ribs and a “large[,] ragged laceration” on her liver, which

caused large amounts of internal bleeding. Smith also had a

hematoma that was “diffuse across the entire scalp,” as well as

subdural and subarachnoid hemorrhages in her brain. The fifth

cervical vertebra in her neck was broken, which, in Dr. Wassum’s

opinion, was likely caused by the blunt-force trauma to her chin. Dr.

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319 Ga. 34, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mayo-v-state-ga-2024.