Merritt v. State

310 Ga. 433
CourtSupreme Court of Georgia
DecidedNovember 12, 2020
DocketS20A1190
StatusPublished
Cited by10 cases

This text of 310 Ga. 433 (Merritt 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
Merritt v. State, 310 Ga. 433 (Ga. 2020).

Opinion

310 Ga. 433 FINAL COPY

S20A1190. MERRITT v. THE STATE.

PETERSON, Justice.

Jerry Merritt appeals his convictions for malice murder and

possession of a firearm during the commission of a felony for the

shooting death of Anthony Taylor, following an argument between

the two several hours earlier.1 Merritt argues that his trial counsel

was ineffective and that the trial court erred by failing to give jury

instructions on voluntary manslaughter and duty to retreat and by

1 The crimes occurred on June 6, 2014. On March 10, 2015, a Muscogee

County grand jury returned an indictment charging Merritt with malice murder, felony murder predicated on aggravated assault, aggravated assault, and possession of a firearm during the commission of a felony. A jury found Merritt guilty of all counts at a February 2017 trial. The trial court sentenced Merritt to life without parole for malice murder, as well as a consecutive five- year sentence for the firearms offense. The felony murder count was vacated by operation of law, and the aggravated assault count merged into malice murder. Merritt filed a motion for new trial through trial counsel on February 13, 2017, and amended the motion through appellate counsel on November 6, 2019. Following a hearing on November 26, 2019, the trial court denied the motion in an order entered on February 3, 2020. Merritt filed a timely notice of appeal, and the appeal was docketed to this Court’s August 2020 term and submitted for a decision on the briefs. allowing the prosecutor to ask leading questions. We conclude that

any deficient performance by counsel did not prejudice Merritt’s

case, that any error by the trial court in allowing leading questions

was harmless, and that the trial court did not plainly err in refusing

to give the requested instructions. We affirm.

The evidence presented at Merritt’s trial showed the following.2

Merritt and Taylor both frequently spent time at the Pure Gas

Station on Fort Benning Road in Muscogee County. Merritt was frail

and skinny, weighing about 110 pounds, while Taylor stood over six

feet tall and weighed at least 222 pounds. The two men ostensibly

were friends, although Merritt’s sister testified that on occasion

Taylor would beat Merritt up or steal his money, and another

defense witness testified that he witnessed Taylor making violent

threats toward Merritt.

In the early morning hours of June 6, 2014, around 1:00 or 1:30,

Merritt and Taylor had an argument at the gas station. Merritt

2 Because this case requires an assessment of the harmful or prejudicial

effect of alleged trial court error and deficient performance by counsel, we lay out the evidence in detail and not only in the light most favorable to the verdict. 2 entered the store carrying a stick, followed by Taylor, who was

carrying a pipe. Taylor struck Merritt in the face with the pipe,

bloodying Merritt’s face. Merritt ran outside and left in a friend’s

vehicle. Upon returning home, Merritt showed his sister his injuries,

and the two siblings drove around looking for Taylor. The search was

unsuccessful, and Merritt’s sister dropped him off near the gas

station. Before his sister left, Merritt told her that he loved and

missed her and would “not be home.”

Later that morning at the gas station, Merritt told a friend

about the fight with Taylor and that he planned to kill Taylor the

next time he saw Taylor. Around 9:00 a.m., Taylor arrived at the gas

station. Taylor got out of the car and began walking toward the store

where Merritt was standing. Soon after approaching Merritt, Taylor

turned away and started running. Merritt chased Taylor around the

outside of the store, shooting at him multiple times. Taylor ran

across the street, where he collapsed. Merritt proceeded down a side

street, but returned shortly thereafter and turned himself in to

police. He had a visible laceration above his eye at the time. Taylor

3 died of a single gunshot wound to the back.

Questioned by police, Merritt was read his Miranda3 rights and

agreed to be interviewed. Merritt reported being bullied repeatedly

by Taylor. He said that, after the incident in which Taylor hit him

with a pipe, he made up his mind that he was going to kill Taylor if

Taylor returned to the store. Merritt said he retrieved his gun when

he returned home that morning. He admitted chasing and shooting

Taylor, saying that he fired the gun until he ran out of bullets.

Merritt at one point claimed that Taylor had a knife in his hands

when he got out of the truck, but later admitted that was not true.

Merritt acknowledged that Taylor did not say anything to him when

he got out of the truck, explaining that Taylor did not have an

opportunity to do so. When told that Taylor was dead, Merritt

responded that he was not going to “shed a tear” because “God don’t

like ugly.” Merritt ultimately led police to the gun he used to shoot

Taylor; the revolver’s cylinder had five spent rounds.

1. Although Merritt does not challenge the sufficiency of the

3 Miranda v. Arizona, 384 U.S. 436 (86 SCt 1602, 16 LE2d 694) (1966).

4 evidence, we have independently reviewed the record and conclude

that the evidence presented at trial was legally sufficient to

authorize a rational trier of fact to find beyond a reasonable doubt

that he was guilty of the crimes of which he was convicted. See

Jackson v. Virginia, 443 U.S. 307, 319 (99 SCt 2781, 61 LE2d 560)

(1979).4

2. Merritt first argues that trial counsel was ineffective by

failing to put forth a clear defense and failing to object properly to

the State’s impeachment of its own witness. We conclude that

Merritt has not shown deficient performance by counsel as to the

first issue, and that he has not shown prejudice as to the second.

To prevail on a claim of ineffective assistance of counsel,

Merritt must show both that his trial counsel’s performance was

deficient and that this deficiency prejudiced his defense. See

Strickland v. Washington, 466 U.S. 668, 687 (104 SCt 2052, 80 LE2d

4 We remind litigants that the Court will end its practice of considering

sufficiency sua sponte in non-death penalty cases with cases docketed to the term of court that begins in December 2020. See Davenport v. State, 309 Ga. 385, 392 (4) (846 SE2d 83) (2020). The Court began assigning cases to the December term on August 3, 2020. 5 674) (1984). “To establish deficient performance, [Merritt] must

overcome the strong presumption that his . . . counsel’s conduct falls

within the broad range of reasonable professional conduct and show

that his counsel performed in an objectively unreasonable way” in

the light of all of the circumstances. Smith v. State, 296 Ga. 731, 733

(2) (770 SE2d 610) (2015) (citation and punctuation omitted). To

establish prejudice, Merritt “must show that there is a reasonable

probability that, but for counsel’s unprofessional errors, the result

of the proceeding would have been different.” Strickland, 466 U.S.

at 694. Merritt must prove both prongs of the Strickland test, and if

he fails to prove one prong, “it is not incumbent upon this Court to

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310 Ga. 433, Counsel Stack Legal Research, https://law.counselstack.com/opinion/merritt-v-state-ga-2020.