STATE OF GEORGIA v. FEDERAL DEFENDER PROGRAM, INC.

CourtSupreme Court of Georgia
DecidedJune 2, 2026
DocketS26A0364
StatusPublished

This text of STATE OF GEORGIA v. FEDERAL DEFENDER PROGRAM, INC. (STATE OF GEORGIA v. FEDERAL DEFENDER PROGRAM, INC.) 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
STATE OF GEORGIA v. FEDERAL DEFENDER PROGRAM, INC., (Ga. 2026).

Opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.

In the Supreme Court of Georgia No. S26A0364 STATE OF GEORGIA et al. v. FEDERAL DEFENDER PROGRAM, INC. et al.

On Appeal from the Superior Court of Fulton County No. 2022CV364429

Argued: March 18, 2026  Decided: June 2, 2026

MCMILLIAN, Justice. Virgil Delano Presnell, Jr., has been on Georgia’s death row for decades. 1 After an execution order issued for him in April 2022, the Federal Defender Program, Inc. (“Federal Defender”), 2 filed an action for breach of contract on its own behalf against the State of Georgia and Christopher M. Carr in his official capacity as Attorney General (collectively, the “State”), claiming that the State breached an agreement about the timing and procedures that the State would follow in resuming executions for certain

1 See Presnell v. State, 274 Ga. 246 (2001), cert. denied, 535 US 1059 (2002). 2 The Federal Defender is a domestic non-profit corporation whose Capital Habeas Unit represents death row inmates in federal post-conviction proceedings and in state clemency proceedings. Presnell and the Georgia Ap- pellate Practice and Educational Resource Center, Inc., a domestic non-profit corporation whose attorneys represent death row inmates in state habeas pro- ceedings and in state clemency proceedings, later moved to intervene in the lawsuit, which was granted. We refer to these three collectively as the “Appel- lees.” death row inmates after the COVID-19 pandemic (the “Agree- ment”). In a prior opinion, this Court held that the Agreement was valid and enforceable and that the trial court did not abuse its discretion in granting an interlocutory injunction, which pro- hibited the State from pursuing execution orders for inmates cov- ered by the Agreement and which effectively stayed Presnell’s ex- ecution. 3 State v. Fed. Defender Program, Inc., 315 Ga. 319, 355 (2022) (“Federal Defender I”). The matter now returns on direct appeal from the trial court’s grant of partial summary judgment, concluding that one Agreement condition—that is, whether COVID-19 vaccines are “readily available to all members of the public” (the “Vaccine Con- dition”)—has not been met because vaccines are not approved by the U.S. Food and Drug Administration (“FDA”) for children un- der six months old. Based on this conclusion, the trial court per- manently enjoined the State from resuming certain executions until the conditions and notice requirements of the Agreement are met. The State contends that, in granting partial summary judg- ment to the Appellees and in denying partial summary judgment to the State, the trial court erred by: (1) failing to apply the Agree- ment’s plain language and, instead, substituting a requirement that the Vaccine Condition is not satisfied until the FDA approves COVID-19 vaccines for children under six months old; (2) inter- preting the Vaccine Condition in a manner that results in an in- definite contract; and (3) imposing an overly broad injunction that goes beyond the scope of the Agreement. We conclude that the trial court erred in construing the Vaccine Condition, and that when correctly construed according to its plain language, the undisputed evidence shows no genuine

3 The interlocutory injunction has since remained in place.

2 issue of material fact about the condition’s satisfaction. So we re- verse and remand for further proceedings. 1. The facts are set out in detail in Federal Defender I, but briefly, in that case we held that an e-mail exchange between a deputy attorney general and an attorney employed by the Federal Defender and other capital defense attorneys constituted a writ- ten contract about the timing and procedures that the State would follow in resuming executions for certain death row in- mates after the COVID-19 pandemic. See 315 Ga. at 344. That email exchange, in relevant part, stated as follows: Our office will not pursue an execution warrant from the District Attorney in the below defined cases be- fore: 1) the final COVID19 judicial emergency order entered by the Chief Justice of the Supreme Court of Georgia expires;[ 4] 2) the Georgia Department of Corrections lifts its suspension of legal visitation, and normal visitation resumes; and [3)] a vaccina- tion against COVID19 is readily available to all members of the public.

Id. at 321. It further stated that: the “agreement applie[d] only to death-sentenced prisoners whose petition for rehearing or rehearing en banc was denied by the Eleventh Circuit while the State of Georgia remained under judicial emer- gency order” and that, with one named excep- tion, the Attorney General’s office agreed “not [to]

4 The judicial emergency order was first issued on March 14, 2020, and expired after 15 extensions on June 30, 2021. See Federal Defender I, 315 Ga. at 320 n.3. In the prior appeal, the Appellees conceded that this condition has been met. See id. at 322.

3 pursue an execution warrant of any prisoner ... be- fore a total of at least six months after the time the above-three conditions [we]re met.”

Id. (original internal footnote omitted). The email exchange con- cluded by stating that “the agreement was ‘made with the under- standing that the District Attorney maintain[ed] the sole author- ity to obtain an execution warrant.’” Id. After the trial court granted an interlocutory injunction precluding the State from pursuing executions of inmates covered by the Agreement, concluding that the conditions in the Agree- ment had not been met, the State, on appeal, argued in relevant part that it had substantially complied with the Agreement’s terms and that the trial court erred in granting the interlocutory injunction because “multiple FDA-approved vaccines have been ‘widely available’ since the winter of 2020” and the trial court’s “‘extreme interpretation’ of the term ‘all members of the public’ as including children under five years of age is contrary to the ‘sub- stantial compliance’ rule.” Federal Defender I, 315 Ga. at 351. However, we disagreed with the State’s position, concluding that “the Agreement’s plain language, drafted by the State, places no limitation on the age of who is considered a member of the public.” Id. We further concluded that, because the Agreement was en- tered in April 2021, regardless of the level of vaccine availability in the winter of 2020, it could not have been what the parties in- tended to satisfy the Agreement. Id. After this Court affirmed the trial court’s interlocutory rul- ing, the parties agreed to litigate the remaining issues separately, starting with the Vaccine Condition. 5 After discovery, the parties

5 The Agreement’s condition regarding inmate visitation has not yet been litigated.

4 cross-moved for partial summary judgment. In its motion, the State argued that the Vaccine Condition has been met, and in the alternative, that the condition had been substantially complied with since March 2023, which is when the Fulton County Supe- rior Court lifted its COVID-19-related restrictions after recogniz- ing that “vaccines are now available to all Georgians,” and when vaccines became “readily available” to all persons six months old and older who are eligible to receive a COVID-19 vaccine.

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