Oliver v. State

842 S.E.2d 847, 308 Ga. 652
CourtSupreme Court of Georgia
DecidedMay 4, 2020
DocketS20A0489
StatusPublished
Cited by5 cases

This text of 842 S.E.2d 847 (Oliver 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
Oliver v. State, 842 S.E.2d 847, 308 Ga. 652 (Ga. 2020).

Opinion

308 Ga. 652 FINAL COPY

S20A0489. OLIVER v. THE STATE.

MCMILLIAN, Justice.

Appellant Jacquan Oliver entered a negotiated plea of guilty to

felony murder in connection with the shooting death of Alexander

Mixon.1 He now appeals from his conviction and sentence, arguing

that the trial court abused its discretion in finding a factual basis

for his guilty plea and in determining that his guilty plea was

voluntarily, knowingly, and intelligently made. Because Oliver’s

1 The crimes occurred on November 24, 2018. In December 2018, a Dougherty County grand jury indicted Oliver and five others – Jacquarius Oliver, Jacquavious Oliver, Jaylen Miller, Iren Carter, and Mickee Carter – for malice murder, felony murder predicated on aggravated assault, conspiracy to commit armed robbery, armed robbery, aggravated assault, possession of a firearm during the commission of a felony, violation of the Street Gang Terrorism and Prevention Act, and first degree forgery. Oliver and Jacquarius Oliver were separately indicted for possession of a handgun by a person under the age of 18. Jacquavious Oliver was separately indicted for tampering with evidence. On September 29, 2019, Oliver entered a negotiated plea of guilty to felony murder and was sentenced to serve life in prison with the possibility of parole. As to Oliver, the remaining counts were nolle prossed. After Oliver filed a timely notice of appeal on October 11, 2019, the case was docketed to this Court’s term beginning in December 2019 and thereafter submitted for a decision on the briefs. claims are without merit, we affirm.

1. Oliver’s first claim — that the trial court abused its

discretion in finding a sufficient factual basis for his plea — is

clearly belied by the record. At Oliver’s guilty plea hearing, the State

proffered the following evidence. On November 24, 2018, police

officers responded to a vacant home in Albany where Mixon, a

restaurant delivery driver, had been shot through the neck while

attempting to deliver an order; Mixon later died as a result of his

wound.2 Investigating officers determined that the phone used to

place the delivery order belonged to the mother of co-indictee Jaylen

Miller and that Miller was in possession of the phone when the order

was placed. During interviews with the Albany Police Department,

Miller explained that the co-indictees had placed the order and

planned to offer the delivery driver counterfeit money. If the driver

refused to accept the counterfeit bills, they planned to rob the driver

of the food. Miller drove the group to the vacant home, and Oliver

and co-indictee Iren Carter exited the vehicle to take the food from

2 The record does not disclose further details of the shooting. Mixon. Miller also told police that after the shooting, he and his co-

indictees went to Jacquavious Oliver’s house in Albany where Oliver

left the gun. Officers executed a search warrant at the address and

recovered the gun used in the crime, which Jacquavious Oliver

admitted to having hidden in a cereal box.

Oliver, Jacquarius Oliver, Iren Carter, and Mickee Carter each

made incriminating statements to police. Oliver admitted both that

he owned the gun used in the murder and that he participated in

the murder, although he identified Iren Carter as the shooter. Iren

Carter, on the other hand, identified Oliver as the shooter. The State

also noted that three of Oliver’s co-indictees, all of whom entered

guilty pleas to crimes arising from the shooting, had stated at their

plea hearings that Oliver admitted to them that he shot the victim.

Also, when Oliver and Iren Carter returned to Miller’s vehicle after

the shooting, Iren Carter carried the food while Oliver held the gun.3

Following the State’s recitation of facts, the trial court asked

3 The State explained at Oliver’s guilty plea hearing that two of Oliver’s

co-indictees testified to this fact at their own guilty plea hearings. Oliver, under oath, whether he had heard the State’s recitation of

facts and whether Oliver was pleading guilty to the murder of

Mixon, as established by those facts. Oliver answered both questions

in the affirmative. The trial court found on the record that there was

a sufficient factual basis for Oliver’s guilty plea and thereafter

accepted the plea.

Oliver now argues that the factual basis for his guilty plea was

inadequate because, during his interview with police, he had

identified Iren Carter as the shooter. Uniform Superior Court Rule

33.9 provides that a trial court, before entering a judgment upon a

guilty plea, must make an “inquiry on the record as may satisfy the

[trial court] that there is a factual basis for the plea.” “The rule

requires nothing more than that the trial court make itself aware of

the factual basis of the plea.” Freeman v. State, 297 Ga. 146, 150 (3)

(771 SE2d 889) (2015) (citation and punctuation omitted).

Here, the State proffered a detailed factual basis that

established Oliver’s guilt, at a minimum, as a party to the crime of

felony murder. Specifically, the facts recited by the State showed that Oliver participated in planning the crime, that he was one of

the two participants to exit the vehicle and confront the victim, that

he provided the gun used to shoot the victim, that he hid the gun at

Jacquavious Oliver’s house after the shooting, and that he admitted

to at least three of his co-indictees that he shot Mixon. These facts

establish a sufficient factual basis for Oliver’s guilty plea to felony

murder, “either as a direct participant or as a party to the crime.

The trial court’s acceptance of [Oliver’s] plea establishes that it was

satisfied with the recitation presented at the plea hearing, and we

see no error in that finding.” Roberts v. State, 298 Ga. 331, 331-332

(1) (782 SE2d 1) (2016) (citation omitted). See also Williams v. State,

304 Ga. 658, 661 (1) (821 SE2d 351) (2018) (“Whether a person is a

party to a crime may be inferred from that person’s presence,

companionship, and conduct before, during, and after the crime.”

(citation and punctuation omitted)); Tate v. State, 287 Ga. 364, 367

(1) (b) (695 SE2d 591) (2010) (concluding adequate factual basis for

appellant’s guilty plea was presented “despite the existence of

several contradictory accounts of the crimes that had been given previously by [the appellant] and his [co-defendants]”).

2. Oliver also asserts that the trial court erred in finding that

his guilty plea was made voluntarily, knowingly, and intelligently

because the trial court failed to engage in a colloquy with him

regarding the privilege against self-incrimination, the right of

confrontation, and the right to a trial by a jury of his peers and

instead asked only whether he understood “all of [his] legal rights.”

It is well settled that, “[w]hen a judgment of conviction and sentence

are entered upon a plea of guilty, the record must establish that the

defendant at the time of his plea was aware of the essential

constitutional protections . . . that he waives by pleading guilty and

consenting to judgment without a trial.” Mims v. State, 299 Ga. 578,

581 (2) (a) (787 SE2d 237) (2016) (citation and punctuation omitted).

Viewing the record as a whole, we conclude that Oliver’s claim is

without merit.

Although Oliver correctly asserts that the trial court failed to

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842 S.E.2d 847, 308 Ga. 652, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oliver-v-state-ga-2020.