Adams v. State

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ADAMS v. THE STATE.

No. S23A1207

Supreme Court of Georgia

January 17, 2024

ELLINGTON, JUSTICE

A Fulton County jury found Isaiah Adams ("Isaiah") guilty of malice murder and other offenses in connection with the shooting death of Laron Lowe and the aggravated assault of Ronda Dobson.^[1] Isaiah contends that the State's evidence was insufficient to support his convictions beyond a reasonable doubt and that the verdicts were contrary to the "law and evidence" as well as "contrary to the principles of justice, fairness, and equity." He also contends that the trial court erred in admitting certain evidence, and that trial counsel was constitutionally ineffective. For the reasons explained below, we affirm the trial court's order denying his motion for a new trial.

The evidence presented at trial showed the following. On August 21, 2016, Lowe, who was sitting in the passenger seat of a car driven by his fiancee, Dobson, was killed when shots were fired from a white car that had followed the couple from the 29 Degrees nightclub, an after-hours club in Fulton County where they both worked. The prosecution presented video evidence, witness testimony, and the defendants' own admissions to show that Leon Adams ("Leon") Isaiah, and Malcolm Pitts were in the white car. The State also presented evidence from which the jury could infer that the shooting may have been motivated by an argument that occurred earlier in the nightclub. The nightclub's general manager Omari Ward, testified that around 6:00 a.m., as he began ushering people out of the nightclub, a server came up to him and told him that Leon and Isaiah were arguing with a bartender over who could drink the most. Ward - who is Isaiah's cousin - approached the men and asked them to leave. Ward assumed the argument was not serious. Other witnesses testified, however, that the argument had gotten "heated" and "there was some pushing and shoving."

Ward testified that he escorted the Adams brothers outside at about 6:45 a.m. and then went back inside to work. A video recording from a security camera outside the club showed Ward stepping outside briefly with the brothers, talking with them, and then going back inside the club at 6:52 a.m. At trial, Ward identified the brothers from the video recording which was played for the jury. He also pointed out the brothers' friend, Pitts, who was wearing a white shirt. Lowe is also visible on the video recording, but Ward testified that he did not witness any interaction between Lowe, Pitts, and the Adams brothers. Lowe, who was Ward's best friend, worked as a parking lot attendant.

Dobson worked at the nightclub as a security guard. After the nightclub closed, Dobson picked up her pay, left the building, and walked toward her black Chevy Tahoe. She testified that she stopped in the parking lot to talk to Lowe and told him she would wait for him to get off work. At about 6:55 a.m., Lowe got in the front passenger seat of Dobson's car, and the two drove off. Dobson testified that she saw a white car idling nearby, but she thought the driver was just letting her leave the parking area ahead of them. Dobson said that, as she turned left out of the parking area, she did not notice anyone behind her. Video surveillance, however, showed that the white car - later identified as a white Ford Escape - also turned left, following her. After driving a few blocks away from the club, Dobson noticed the white car pulling up along the left side of her car. She testified that, because she was driving slowly, she assumed the driver was passing her. The driver, however, pulled parallel to her car and matched her speed. Then she saw an arm extending from the open front, passenger-side window. The person wore a long-sleeved, white or light-colored shirt and held a gun in his hand. And then she heard the first gunshot.

Dobson immediately turned and yelled to Lowe: "Baby, they are shooting at us." But Lowe was unresponsive, having been shot in the left temple. Dobson testified that she heard approximately four to six gunshots thereafter. The bullets shattered the driver's side windows and punctured holes in the driver's side quarter panel and the hood of the car. The driver's-side, rear caution light was also damaged by the gunfire. Dobson slowed down and stopped, but the shooting continued. When she saw the white car's brake lights come on as it slowed and then stopped, she feared the driver would turn around to come after her. She quickly backed up, turned around, and drove back to the nightclub to get help. When she arrived at the nightclub and saw that people were still outside, including Ward, she honked her car's horn and began screaming for help. Dobson got out of her car and fell to the ground, shouting: "Please don't let him be dead." Ward ran to help Lowe, but there was nothing he could do. Lowe died in the parking lot.

When the police arrived at the nightclub, Ward showed them the video recordings from the nightclub's security cameras. As Ward looked at the recordings with the officers, he identified Pitts and the Adams brothers getting into a white Ford Escape that matched the description of the car Dobson said had followed her and Lowe. Isaiah got into the driver's seat, Pitts got into the front passenger seat, and Leon got into the back passenger seat. Ward told the police that, during the weekend before the shooting, he had seen Isaiah with a .380-caliber handgun and Leon with a pink revolver. He also testified that Pitts was known to carry a firearm, though he did not see him with one that night. After reviewing the nightclub's video recordings, Ward got into a patrol car with officers and directed them to the Adams brothers' home. When they arrived, they saw a white Ford Escape in the driveway. An officer testified that the car matched the car seen in the nightclub's security video recordings.

While Ward showed the officers where the Adams brothers lived, other officers found and gathered evidence from the roadway where Dobson said the shooting had occurred. The police recovered 11 shell casings from the roadway. They recovered five 9mm shell casings, four .40-caliber shell casings, and two .380-caliber shell casings.

On August 22, 2016, the police went to the Adams home to execute an arrest warrant for Leon, who, unrelated to the shooting, had violated the terms of his probation. Officers knocked at the front door, and a woman permitted them to enter. When they showed the woman the warrant, she claimed nobody else was in the residence. But then Xavier Adams - Isaiah's twin brother - walked out and stood next to her. A detective testified that they searched the house for Leon, checking places where it was common for people to hide. The officers found Isaiah hiding on the floor in a bedroom and detained him there. They found Leon in the closet of another room, curled up inside a large storage bin. During their search for the brothers, the officers saw two handguns. They saw one of the weapons in Isaiah's room when they lifted a mattress to look under it; the other was in an open backpack on the floor of Leon's room. Upon seeing the weapons, the officers secured the residence. A few hours later, the officers obtained a search warrant for the residence.

During the search that followed, officers found several more firearms (including handguns, long guns, and semi-automatic rifles), as well as various types of ammunition. They recovered clothing that appeared to match clothing worn by the brothers on the day of the shooting as well as a paper copy of Pitts's driver's license.

The firearms recovered included a SAR Arms 9mm handgun. Further investigation revealed that this gun had been stolen from its owner a few days before the shooting. The owner testified that he kept the gun in the door panel of his truck. The last time he saw the gun was during a lunch break, when he was accompanied in his car by his coworker, Xavier Adams. The officers also recovered several cell phones during the search of the Adams home. One of those phones, which was found in Isaiah's room, had been used on the evening after the shooting to conduct over three dozen Internet browser searches for information regarding the shooting and Lowe's death.

Pursuant to a search warrant, a GBI crime scene investigator processed the white Ford Escape for evidence. The investigator recovered an extended handgun magazine in the pocket on the back of the driver's seat. The magazine contained 13 .380-caliber bullets. The investigator recovered a 9mm shell casing from beneath the driver's seat and cut a piece of cloth from the interior of the car. The cloth tested positive for gunshot residue.

After Pitts was arrested, the police secured a search warrant for his residence. During the search, the police found a white hoodie matching what Pitts was seen wearing on the night of the shooting. The hoodie tested positive for gunshot residue.

The medical examiner who performed Lowe's autopsy testified that Lowe had a gunshot entrance wound to the left side of his head. The bullet traveled through his brain and came to rest against the right side of his skull. The medical examiner determined that the gunshot wound to Lowe's head was the cause of his death. The medical examiner recovered the bullet and turned it over to the GBI.

A GBI firearms examiner analyzed the ballistics evidence collected from the scene of the shooting, from the medical examiner and from the Adams home. The examiner determined that the 9mm shell casing recovered from beneath the driver's seat of the Ford Escape, along with three of the 9mm shell casings recovered from the scene of the shooting, were all fired from the 9mm SAR Arms pistol recovered from the Adams residence. The firearms examiner...