State v. CASH

CourtSupreme Court of Georgia
DecidedOctober 30, 2017
DocketS17A1059
Status200

This text of State v. CASH (State v. CASH) 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 v. CASH, (Ga. 2017).

Opinion

302 Ga. 587 FINAL COPY

S17A1059. THE STATE v. CASH et al.

HINES, Chief Justice.

This is an appeal by the State from an order of the superior court

sustaining a motion by mother and daughter murder defendants Elgerie Mary

Cash and Jennifer Michelle Weathington denominated “Double Jeopardy Plea

in Bar,” which challenged the sufficiency of the evidence of their guilt at trial.1

For the reasons that follow, we reverse and remand with direction.

Procedural History

Cash and her daughter Weathington were tried jointly before a jury in the

Superior Court of Paulding County in October 2013 and found guilty of malice

murder, felony murder, two counts of aggravated assault, and possession of a

firearm during the commission of a felony in connection with the fatal shooting

1 In this same document, the superior court also reconsidered a previous order on defendants’ motion to dismiss for failure to provide a speedy trial, set aside such order, and issued an amended order denying the motion to dismiss based upon the alleged violation of the right to a speedy trial. However, this appeal addresses only the sustaining of the “Double Jeopardy Plea in Bar.” of Lennis Jones. Each woman was sentenced to life in prison for malice murder

and a consecutive term of five years in prison for the firearm possession.

Claiming that Jones accidentally shot himself, Cash and Weathington each filed

a motion for new trial, which motions were subsequently amended. Following

a joint hearing on the motions, as amended, in May 2014 the superior court

entered separate orders granting each defendant a new trial, and then

approximately a week later issued a joint amended order granting new trials to

the defendants and vacating their convictions and sentences. The superior court

did so after finding that the defendants received ineffective assistance of counsel

at trial and based upon the general grounds, i.e., that the verdicts were contrary

to the principles of justice and equity and decidedly and strongly against the

weight of the evidence. See OCGA §§ 5-5-20,2 5-5-21.3 The State appealed the

grants of new trials to the defendants, and this Court affirmed, determining that

2 OCGA § 5-5-20 provides: In any case when the verdict of a jury is found contrary to evidence and the principles of justice and equity, the judge presiding may grant a new trial before another jury. 3 OCGA § 5-5-21 provides: The presiding judge may exercise a sound discretion in granting or refusing new trials in cases where the verdict may be decidedly and strongly against the weight of the evidence even though there may appear to be some slight evidence in favor of the finding.

2 the superior court “who observed the trial and who had the duty to examine the

conflicts in the evidence and the credibility of the witnesses in ruling on the

general grounds, did not abuse its broad discretion in granting [defendants] new

trials on the general grounds.” State v. Cash, 298 Ga. 90, 97 (2) (c) (779 SE2d

603) (2015) (“Cash I”).4 Upon return of the remittiturs, Weathington filed her

“Double Jeopardy Plea in Bar,” claiming that the evidence at trial was

insufficient under the standard of Jackson v. Virginia, 443 U. S. 307 (99 SCt

2781, 61 LE2d 560) (1979), and consequently, that the State could not again put

her in jeopardy for the same offenses; Cash adopted her daughter’s motion as

her own. The superior court sustained the motion, finding that the defendants

had not waived their rights to challenge the sufficiency of the evidence of their

guilt of the crimes charged under Jackson v. Virginia, and that the evidence was

insufficient under such standard; it expressly directed that a judgment of

acquittal be entered as to both defendants on all counts of the charging

4 Prior to the scheduled hearing on the new trial motions, the State filed a motion to recuse the trial judge, and the trial judge dismissed the recusal motion as legally insufficient without referring it to another judge, and orally denied the State’s request for a certificate of immediate review. In Cash I, the State also attempted to appeal the denial of its motion to recuse, but this Court determined that it did not have jurisdiction to review that ruling and dismissed that portion of the State’s appeal. Id. at 93-94 (1).

3 indictment.5

Jurisdiction of the Appeal

As this Court reaffirmed in Cash I, “[a]ppeals by the State in criminal

cases are construed strictly against the State and ‘the State may not appeal any

issue in a criminal case, whether by direct or discretionary appeal, unless that

issue is listed in OCGA § 5-7-1.’”6 Id. at 91 (1) (a) (citation omitted).

5 Defendants had filed cross-appeals to the State’s original appeal in Cash I, challenging the denial of their motions for new trial on the basis of insufficiency of the evidence; however, they were permitted to withdraw the cross-appeals because the superior court had not entered a written order on that ground but had merely remarked in its oral ruling from the bench at the motion-for-new-trial hearing that the evidence was legally sufficient under Jackson v. Virginia to support the defendants’ convictions. 6 Former OCGA § 5-7-1 in effect at the times of filing the judgment at issue and the notice of appeal in 2016 provided: (a) An appeal may be taken by and on behalf of the State of Georgia from the superior courts, state courts, and juvenile courts and such other courts from which a direct appeal is authorized to the Court of Appeals and the Supreme Court in criminal cases and adjudication of delinquency cases in the following instances: (1) From an order, decision, or judgment setting aside or dismissing any indictment, accusation, or a petition alleging that a child has committed a delinquent act, or any count thereof; (2) From an order, decision, or judgment arresting judgment of conviction or adjudication of delinquency upon legal grounds; (3) From an order, decision, or judgment sustaining a plea or motion in bar, when the defendant has not been put in jeopardy; (4) From an order, decision, or judgment suppressing or excluding evidence illegally seized or excluding the results of any test for alcohol or drugs in the case of motions made and ruled upon prior to the impaneling of a jury or the defendant being put in jeopardy, whichever occurs first; (5) From an order, decision, or judgment excluding any other evidence to be used by the state at trial on any motion filed by the state or defendant at least 30 days prior to trial and ruled on prior to the impaneling of a jury or the defendant being put in jeopardy, whichever occurs first, if:

4 Applicable OCGA § 5-7-1 (a) (3)7 provides that the State may appeal to this

Court from “an order, decision, or judgment sustaining a plea or motion in bar,

when the defendant has not been put in jeopardy.” (Emphasis supplied.)

Weathington has moved to dismiss the State’s appeal, arguing that in Cash I this

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Related

United States v. Jorn
400 U.S. 470 (Supreme Court, 1971)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Bullard v. State
436 S.E.2d 647 (Supreme Court of Georgia, 1993)
State v. Morrell
635 S.E.2d 716 (Supreme Court of Georgia, 2006)
Moore v. State
340 S.E.2d 888 (Supreme Court of Georgia, 1986)
Ratana v. State
678 S.E.2d 193 (Court of Appeals of Georgia, 2009)
State v. Martin
603 S.E.2d 249 (Supreme Court of Georgia, 2004)
Hill v. State
642 S.E.2d 64 (Supreme Court of Georgia, 2007)
Teasley v. State
704 S.E.2d 800 (Supreme Court of Georgia, 2011)
Manuel v. State
711 S.E.2d 676 (Supreme Court of Georgia, 2011)
Walker v. State
766 S.E.2d 28 (Supreme Court of Georgia, 2014)
Shockley v. State
777 S.E.2d 245 (Supreme Court of Georgia, 2015)
State v. Cash
779 S.E.2d 603 (Supreme Court of Georgia, 2015)
Brown v. State
302 S.E.2d 347 (Supreme Court of Georgia, 1983)
State v. Caffee
728 S.E.2d 171 (Supreme Court of Georgia, 2012)
State v. Cash
807 S.E.2d 405 (Supreme Court of Georgia, 2017)
Adamson v. State
516 S.E.2d 310 (Court of Appeals of Georgia, 1999)

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Bluebook (online)
State v. CASH, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cash-ga-2017.