The Supreme Court of Georgia largely affirmed the conviction of Tony Adams, Jr., for the malice murder of his mother, Belinda Woodson, but overturned key parts of his sentence due to a legal error concerning included offenses. While Adams’s claims of ineffective assistance of counsel were rejected, the high court found that his conviction for aggravated assault should have been merged into the malice murder charge, necessitating a resentencing process.
Adams was convicted in 2021 for the May 2018 stabbing and shooting death of his mother in Dooly County. The jury found him guilty on all counts, including malice murder, felony murder (which was vacated by operation of law), aggravated assault, and weapons possession charges. He was sentenced to life without parole for the murder, plus consecutive terms for other offenses.
Ineffective Assistance Claims Rejected
Adams appealed, arguing his trial attorney provided constitutionally ineffective assistance on several fronts. He claimed counsel failed to adequately investigate his competency to stand trial, neglected to pursue an insanity defense, and made a damaging comment during his own testimony.
The Supreme Court thoroughly examined these claims under the *Strickland v. Washington* standard, which requires showing both deficient performance by counsel and resulting prejudice.
Regarding competency, the Court noted that Adams had undergone a mental health evaluation in 2019, two years before trial, which found him competent, suggesting he was “grossly feigning” psychiatric symptoms due to drug use. Trial counsel testified that nothing observed during their interactions raised doubts about Adams’s competency at the time of trial. Given the existing expert opinion and lack of subsequent red flags, the Court found counsel’s decision not to seek a second evaluation was a reasonable tactical choice, not deficient performance.
Concerning the insanity defense, the Court deferred to trial strategy. Counsel pursued a self-defense theory, partially supported by Adams’s claims (though later contradicted by his own admissions to police). Crucially, the pre-trial evaluation concluded Adams “was able to distinguish right from wrong” and was not under a delusional compulsion. Therefore, choosing a self-defense strategy over an insanity defense was deemed objectively reasonable.
Finally, the Court addressed Adams’s complaint about his attorney’s outburst during his direct testimony. When Adams offered bizarre explanations for the killing—attributing his actions to an “activation of anger,” possession, and an “exorcism”—counsel interjected, asking, “Are you for real here today? Are you expecting us to believe all this nonsense?” While the Court acknowledged this *might* be seen as deficient, it found Adams failed to show prejudice. Given the overwhelming evidence, including Adams’s own admissions that he stabbed and shot his mother, the Court concluded it was not reasonably probable that this comment changed the verdict.
Denial of Post-Judgment Competency Hearing Upheld
Adams also challenged the trial court’s refusal to grant a post-judgment competency hearing requested in his 2024 amended motion for a new trial. The trial court denied the request, noting the existing evaluation found competency and that the inquiry, made over three years after the trial, would not be informative.
The Supreme Court agreed, finding no abuse of discretion. While Adams raised competency issues pre-trial, the existing evaluation favored competency. Coupled with counsel’s assurance of Adams’s ability to assist during trial, and the lack of new expert evidence countering the pre-trial finding, the denial was appropriate.
Merger Error Leads to Vacated Sentences
The most significant ruling involved a procedural error the Court noticed even though Adams did not raise it on appeal: a double jeopardy issue related to sentencing.
Adams was convicted of malice murder (Count 1) and aggravated assault predicated on the stabbing (Count 4). The Court clarified that when aggravated assault is committed using the same facts that establish the murder—in this case, the stabbing contributing to the death—the lesser offense is included in the greater offense and must merge.
The Court exercised its discretion to correct the error, vacating Adams’s conviction and sentence for aggravated assault (Count 4).
This vacation had a cascading effect on the sentence for possession of a knife during the commission of a felony (Count 6). Since the five-year sentence for Count 6 was ordered to run consecutively to the vacated Count 4 sentence, the Court also vacated the sentence for Count 6. The case was remanded to the trial court to resentence Adams on Count 6, allowing it to run consecutively to one of the other valid remaining counts.
The judgment affirming the murder conviction stands, but the case returns to the trial level solely for the purpose of calculating and imposing a new sentence for the weapons charge.