Criminal Law

Georgia Supreme Court Upholds Denial of Plea Withdrawal in Murder Case

Georgia Supreme Court Upholds Denial of Plea Withdrawal in Murder Case

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The Supreme Court of Georgia has affirmed a trial court’s decision to deny Cornelius Murray’s motion to withdraw his guilty plea for the malice murder of Willie Jacox, concluding that the plea was entered knowingly and voluntarily despite Murray’s later claims of misunderstanding and ineffective counsel.

Murray, who pled guilty in February 2023 as part of a negotiated agreement that resulted in a sentence of life with the possibility of parole, challenged the trial court’s ruling nearly two years later. His appeal centered on two main arguments: that his plea was not truly voluntary and intelligent, and that his original defense counsel provided him with ineffective assistance.

The Supreme Court, in an opinion delivered by Justice Colvin on January 5, 2026, found no abuse of discretion by the trial court in rejecting Murray’s bid to undo the plea.

The Facts of the Crime and Plea Agreement

The case stems from a fatal shooting in July 2021. According to the factual basis presented during the plea hearing, Murray and his co-defendant, Natajah Culpepper, encountered the victim, Willie Jacox. Murray reportedly felt disrespected by Jacox due to his interactions with Culpepper, Murray’s girlfriend. Following a setup where Culpepper lured Jacox to meet them, Murray allegedly “unloaded the whole clip,” fatally shooting Jacox. Evidence at the scene included multiple shell casings, witnesses seeing a male rummaging through the victim’s car, and both Murray and Culpepper fleeing the area. Responding officers found a gun smelling of recent use in a backpack carried by Culpepper, and a gunshot residue test on Murray came back positive. Murray also reportedly admitted to the shooting during his police interview.

Under the negotiated plea, the State recommended a sentence of life with the possibility of parole for the malice murder charge. Other related counts were either merged or dismissed (nol prossed).

Questionable Voluntariness at the Guilty Plea Hearing

During the plea colloquy, the trial court meticulously reviewed Murray’s constitutional rights, which Murray confirmed he understood and wished to waive, including his right to a jury trial and the right to remain silent.

However, a critical exchange occurred regarding Murray’s mental state. Murray disclosed he was under psychiatric care and had taken medication that morning. When asked if the medication would impair his understanding, Murray replied uncertainly, “I mean I don’t really know. When I do take the medicine I be okay, but I don’t know.”

Despite this hesitation, plea counsel assured the court that she and her supervising attorney had spent over an hour with Murray that morning ensuring he understood the proceedings and the consequences. The court ultimately found the waiver of rights to be free and voluntary, and Murray affirmed that he was pleading guilty because he was, in fact, guilty. He even offered an apology to the victim’s family, stating, “I wish I never did it. I’m sorry.”

The Basis for Withdrawing the Plea

Murray filed his motion to withdraw the plea shortly after sentencing. His primary claim was that he misunderstood the sentence: he believed a “life with the possibility of parole” sentence guaranteed his release after serving 30 years, rather than understanding it meant a minimum of 30 years before a parole board could even consider his release. He also claimed his counsel was deficient.

At the subsequent hearing, the testimony sharply contrasted. Plea counsel asserted she thoroughly reviewed all discovery, including police interviews, and explained repeatedly that a life sentence with parole meant serving a mandatory minimum of 30 years, with no guarantee of release thereafter. She testified that Murray did not express confusion until *after* the plea was entered, at which point he claimed he thought he would simply be released in 30 years.

Murray painted a different picture, claiming counsel visited only a few times, never provided discovery, and falsely assured him the sentence meant getting out in 30 years. He even alleged his counsel told him to lie to the judge about taking his medication.

The Trial Court’s Credibility Findings

The trial court sided squarely with the plea counsel. It found her testimony “more credible” and characterized Murray’s claims about being misled as an “after the fact concoction.” The court noted that the plea form itself indicated Murray understood the maximum penalty could be life imprisonment, and the prosecutor explicitly stated the recommendation was “life with the possibility of parole.”

The Supreme Court reiterated the standard: after sentencing, a defendant can only withdraw a plea to correct a “manifest injustice.” This requires showing the plea was involuntary or unknowing, or that counsel was ineffective.

The appellate court found that the trial court’s factual findings—which heavily relied on the credibility assessment during the hearing—were supported by the record. The transcript of the plea hearing, the signed plea form, and the counsel’s detailed testimony provided ample basis for the trial judge to conclude Murray understood the consequences of his actions, even if he later regretted the outcome or misinterpreted the parole process.

Regarding the ineffective assistance claim, the Supreme Court noted that Murray failed to show deficient performance because the trial court credited counsel’s testimony that she provided thorough preparation and explained the plea deal repeatedly. Since the trial court was entitled to believe the attorney over the defendant, the ineffectiveness claim also failed.

Ultimately, the Georgia Supreme Court ruled that the trial court did not abuse its discretion, and the denial of the motion to withdraw the guilty plea stands affirmed.

Case Information

Case Name:
MURRAY v. THE STATE

Court:
Supreme Court of Georgia

Judge:
COLVIN, Justice (Delivering Opinion)