Remler v. State

897 S.E.2d 376, 318 Ga. 61
CourtSupreme Court of Georgia
DecidedJanuary 17, 2024
DocketS23A1075
StatusPublished
Cited by1 cases

This text of 897 S.E.2d 376 (Remler 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
Remler v. State, 897 S.E.2d 376, 318 Ga. 61 (Ga. 2024).

Opinion

318 Ga. 61 FINAL COPY

S23A1075. REMLER v. THE STATE.

MCMILLIAN, Justice.

Justin Remler challenges his 2019 conviction for felony murder

in connection with the death of Tristan Mitchell, who was two years

and nine months old.1 Remler contends that the evidence was not

legally sufficient to support the jury’s verdict, that a defense expert

was wrongly prevented from testifying that a preexisting heart

condition was the likely cause of Tristan’s death, that the trial

court’s instruction to the jury on proximate cause was erroneous,

1 Tristan died on September 12, 2016. On May 10, 2017, Remler was

indicted by a Chatham County grand jury for malice murder, felony murder, and aggravated assault. After a trial held from December 16 to 20, 2019, the jury acquitted Remler of malice murder, but it found him guilty of felony murder and aggravated assault. Following a sentencing hearing held on January 17, 2020, the trial court imposed a sentence of life in prison with the possibility of parole for the felony murder and merged the aggravated assault into the felony murder. On January 21, 2020, Remler filed a motion for a new trial, which he amended on February 16, 2022. After conducting a hearing on May 17, 2022, the trial court denied the amended motion on May 1, 2023. Remler filed a timely notice of appeal on May 3, 2023, and this appeal was docketed to the August 2023 term of this Court and was submitted for a decision on the briefs. that the trial court’s instruction regarding the relationship between

the counts of aggravated assault and felony murder was erroneous,

that trial counsel rendered ineffective assistance, and that the

cumulative effect of the trial court’s errors and trial counsel’s

deficiencies requires a new trial. For the reasons set forth below, we

affirm.

The evidence presented at Remler’s trial showed the following.

In August 2016, Remler was dating Courtney Metts, and the pair

frequently exchanged text messages, including about the behavior

of Metts’s son, Tristan, who was two years and nine months old. On

August 2, 2016, Remler texted, “[Y]ou need to just let me keep him

for a few days.” He then suggested, “[S]lap the s**t out of him.”

When Metts texted to complain about Tristan again just over an

hour later, Remler texted: “[G]rr, go in there, grab him, and look him

in the eye. Shake him around, make sure he knows you mean f***ing

business.”

On August 11, 2016, Metts sent Remler a video recording from

earlier that evening of Tristan sitting on the floor intermittently

2 making wailing sounds, and she commented that Tristan was then

in his bed crying. Remler suggested in reply: “Go in there and storm

up to him and grab him hard. Shake him and slap him and tell him

no crying. You have to use force, like more than you think. It’s not

going to hurt him. He’s super tough.” He added, “You don’t actually

have to hurt him. They get the message as long as you use force and

make eye contact and [a] loud voice.” Then just over an hour later,

Remler offered: “I can try to help discipline him. But it will take time

and multiple days with me.” He added, “And I’ll discipline him so

good that by the time he’s done, he’ll want to come home to you so

bad.” Metts responded, “Y’all have to have fun, too, though. He’s only

[nearly] three. If it’s all punishment and no fun he won’t

understand.” Remler replied, “I’m not going to just beat him the

whole time.”

On August 13, 2016, Metts texted Remler: “Don’t spank

Tristan’s a** today. He has bruises on his a** for some reason.”

Remler replied: “I didn’t even spank his butt that hard either for

real. Maybe his butt is more sensitive than anything else. Ha.”

3 Several hours later, Remler texted: “He’s still got those bruises on

his back from the washing machine, I think.” He added, “But I really

didn’t spank his butt that much.”

On August 15, 2016, Tristan showed one of the teachers at his

daycare center a large, protruding bruise on his forehead. The

teacher also discovered bruises on his ear and in his ear that she

thought “looked really bad” and a bruise on his leg or thigh area. She

and the school director then lifted his shirt and saw more bruises on

his back. The director took photographs and reported the matter to

the Division of Family and Children Services (“DFCS”). That same

day, a DFCS worker contacted Metts, who “stated that the child was

on a washer or a dryer and fell off while her boyfriend [Remler] was

watching the child that day.” The DFCS worker instructed Metts to

take Tristan to the emergency room for evaluation, but he took no

further action on the case. Metts texted Remler about the bruises on

Tristan, and Remler replied, “I don’t touch his ears. I knew about

the forehead, and the washer kind of scraped up his back.”

On August 19, 2016, Metts texted Remler about how Tristan

4 had been asking about him, and Remler replied, “I’m surprised he

likes me so much even though I spank and smack him.”

Metts and Remler then apparently took a break in their

relationship, but their relationship had resumed by September 12,

2016, when Remler took Tristan to the house he lived in with his

parents to babysit him while Metts worked. Remler’s mother, who

was suffering from a medical condition and was essentially confined

to her bedroom, later reported that during that day she heard

banging coming from Remler’s bedroom above her own, which she

assumed was Tristan “jumping” or Remler and Tristan

“roughhousing.” At 5:01 p.m., Remler texted Metts, saying: “IDK [I

don’t know] if you felt it or not, but there’s a little bump on

[Tristan’s] head. IDK if he got it from staying with [Tristan’s father]

or what. I just felt it. It’s nothing big but still a bump.” However, at

about this same time, according to his audio-recorded statement to

an investigator, Remler was just discovering that Tristan was

unresponsive following a nap. Remler took Tristan from his own

room to his mother’s room downstairs. His mother, a former nurse,

5 noted that Tristan’s heart was beating rapidly but that he was not

breathing. She performed artificial respiration as she spoke with a

911 operator. A paramedic, who responded to the 911 call, examined

Tristan and noted, “[H]is eyes were fixed and dilated which means

there’s been obviously no oxygen to the brain for some time.” He also

noted “bruising around the eyes” that is indicative of someone not

breathing, and one eye being “bigger than the other, like indicative

of a head injury.” He also testified about Remler’s communication

with him at the scene: “he was changing his story as to what

happened.” Tristan was taken to the hospital where he was

pronounced dead.

Dr. Natasha Grandhi, who performed Tristan’s autopsy, was

called to testify at trial by the State. In addition to numerous minor

injuries, Dr. Grandhi noted a number of bruises and abrasions on

Tristan’s head. An internal examination of the head revealed

bleeding in the muscle tissue in the jaw, “fine . . . pinpoint areas of

bleeding that were scattered through the eyelids,” “subgaleal scalp

hemorrhages” in multiple places, “bleeding on the surface of the

6 brain, a “slightly enlarged” brain indicative of the brain’s self-

healing reaction to an injury, and “a bruise on one of the portions on

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Related

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Bluebook (online)
897 S.E.2d 376, 318 Ga. 61, Counsel Stack Legal Research, https://law.counselstack.com/opinion/remler-v-state-ga-2024.