Neuman v. State

856 S.E.2d 289, 311 Ga. 83
CourtSupreme Court of Georgia
DecidedMarch 15, 2021
DocketS20A1143
StatusPublished
Cited by20 cases

This text of 856 S.E.2d 289 (Neuman 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
Neuman v. State, 856 S.E.2d 289, 311 Ga. 83 (Ga. 2021).

Opinion

311 Ga. 83 FINAL COPY

S20A1143. NEUMAN v. THE STATE.

BETHEL, Justice.

In August 2016, a DeKalb County jury found Hemy Neuman

guilty of the malice murder of Russell Sneiderman and possession of

a firearm during the commission of a felony. This was the second

jury to return guilty verdicts against Neuman as to those offenses.

We reversed Neuman’s convictions following his first trial because

the State had improper access to privileged notes and records of

Neuman’s mental health experts during preparation of the State’s

case. See Neuman v. State, 297 Ga. 501 (773 SE2d 716) (2015).

Neuman now appeals his convictions from his second trial.1 He

1 Neuman’s first trial in 2012 resulted in a guilty but mentally ill verdict

on the malice murder count and a guilty verdict on the firearm possession count. Following our remand in 2015, Neuman was retried from August 1 to 23, 2016, and found guilty on both counts. On August 23, 2016, the trial court sentenced Neuman to serve life in prison without parole for the malice murder count and five consecutive years for the firearm possession count. On September 19, 2016, Neuman filed a motion for a new trial, which he subsequently amended twice. Following a hearing, the trial court denied contends that because the first jury returned a verdict of guilty but

mentally ill on the malice murder count,2 the second jury was

collaterally estopped from returning a guilty verdict that did not

include a finding of mental illness on that count. Neuman further

contends that the District Attorney’s Office for the Stone Mountain

Judicial Circuit should have been disqualified from representing the

State in his second trial because the office had access to the

privileged information that resulted in the reversal of his first

convictions. He also alleges that the trial court erroneously limited

his counsel’s examination of two defense witnesses. Finally,

Neuman argues that, to the extent his trial counsel did not preserve

objections during examination of these witnesses, such failure

constituted ineffective assistance of counsel. Seeing no reversible

error, we affirm.

Neuman’s motion on July 31, 2019. Neuman filed a timely notice of appeal on August 29, 2019. This case was docketed to this Court’s August 2020 term and was orally argued on September 16, 2020. 2 In Georgia, juries presented with evidence of a defendant’s mental

illness may return a verdict of guilty but mentally ill. See OCGA § 17-7-131 (b) (1) (D); see also Morgan v. State, 307 Ga. 889, 891 (1) (838 SE2d 878) (2020).

2 Sufficiency of the Evidence

1. Although not raised by Neuman as error in this appeal, as

has been our customary practice, we consider the sufficiency of the

evidence presented against him at his second trial.3 The evidence of

how the fatal shooting occurred was similar in the two trials. As set

forth by this Court in our first review of Neuman’s case, this

evidence is summarized as follows:

Shortly after 9:00 a.m. on November 18, 2010, Russell Sneiderman was walking to his car outside of a Dunwoody daycare center after having just dropped off his son, when Neuman approached and shot him four [or] five times in the neck and torso. Sneiderman was pronounced dead approximately an hour later. Neuman does not dispute that he planned and perpetrated Sneiderman’s murder. He admitted [to police and psychologists that] he had an affair with Sneiderman’s wife, planned Sneiderman’s murder, purchased a disguise and a gun, rented a car, shot Sneiderman, threw the gun in a lake, disposed of the disguise, asked the person from whom he had purchased the gun to lie to the police, and lied to the police himself. Additionally, witnesses from the scene at the daycare identified Neuman as the shooter during trial. Ballistic

3 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 began in December 2020. See Davenport v. State, 309 Ga. 385, 399 (4) (846 SE2d 83) (2020). The Court began assigning cases to the December term on August 3, 2020. 3 evidence showed that the bullets that killed Sneiderman matched the gun Neuman had purchased.

Neuman, 297 Ga. at 501-502 (1).

The key issue during both trials involved evidence of

Neuman’s mental condition at the time of the shooting. To support

Neuman’s plea of not guilty by reason of insanity, Neuman engaged

the services of psychologist Dr. Andrea Flores. In the second trial,

Dr. Flores testified (largely as she did in the first trial) that Neuman

suffered from bipolar disorder with psychosis. Dr. Flores opined that

Neuman experienced delusions, which made him believe he needed

to kill Sneiderman in order to protect Sneiderman’s children from

harm by their father. She testified that the delusions also compelled

Neuman to lie to the police and make efforts to conceal his identity

so that Sneiderman’s wife would not know how Neuman killed her

husband. Dr. Flores testified that she formed her professional

opinions following an extensive review of Neuman’s medical records,

review of documents and correspondence from Neuman, interviews

with Neuman and others, and a review of tests administered to

4 Neuman by other professionals. As she did at the first trial, Dr.

Flores testified about her qualifications and the extent of her

investigation and findings in regard to Neuman’s mental health.

As in the first trial, to counter Dr. Flores’s testimony, “the

State presented testimony from numerous friends, family members,

and co-workers of Neuman who stated that they had never

witnessed any symptoms or behaviors consistent with mental illness

involving manic episodes, delusional thinking, or hallucinations.”

Neuman, 297 Ga. at 502 (1). Additionally, for the second trial,

forensic psychologist Dr. Don Hughey and forensic psychiatrist Dr.

Joseph Browning were engaged by the State to evaluate Neuman’s

ability to distinguish right from wrong at the time of the crimes and

whether Neuman was acting under a delusional compulsion when

he killed Sneiderman. During these evaluations, Neuman admitted

killing Sneiderman. Both State experts testified that there was no

evidence that Neuman suffered from a major mental health disorder

or was delusional on the day of the shooting and explained to the

jury that Neuman’s actions showed that he could distinguish

5 between right and wrong. Both experts also testified that Neuman

showed signs of malingering4 during evaluations and was not

suffering from any mental illness. Both testified that Neuman’s

hyper-sexuality, the elaborate nature of the shooting, the efforts

Neuman made to cover it up, and the inconsistent manner in which

Neuman described his delusions made it clear that Neuman was not

suffering from any mental delusions at the time of the shooting.

At the second trial, the State also presented a recording of a

jail phone call between Neuman and his sister that occurred on

August 4, 2016, during the first trial. In the recording, Neuman

expressed a preference for being found not guilty by reason of

insanity because he would prefer to stay in a mental health facility

instead of a prison.

As with the evidence presented during Neuman’s first trial, we

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856 S.E.2d 289, 311 Ga. 83, Counsel Stack Legal Research, https://law.counselstack.com/opinion/neuman-v-state-ga-2021.