ALBANY, GA (WALB) -
John Woods, who was convicted of murdering Travis Sauls in 2009, was granted a new trial by justices of the Supreme Court of Georgia. The court ruled that the jury which found Woods guilty should have received instructions for the trial judge regarding self-defense laws in Georgia.
Here is a summary of the case provided by the Supreme Court of Georgia-
WOODS V. THE STATE (S 12A1143)
The Supreme Court of Georgia has ordered a new trial for a man convicted of murder in Berrien County.
In today's unanimous opinion, Justice P. Harris Hines writes that the high court has reversed the man's conviction because the trial court failed to instruct jurors on the law of self-defense prior to their deliberations, as the defense attorney had requested.
"Absent such an instruction, the jury was not provided ‘with the proper guidelines for determining guilt or innocence,'" today's opinion says.
According to the evidence at trial, in October 2009, David Woods – the brother of John Dennis Woods – was hunting on his father's property in Madison County, FL, just across the Georgia state line. He saw unusual tire tracks and footprints in the area, investigated and discovered ashes with bone fragments. Woods called a friend who was a sheriff's deputy in North Florida. Sifting through the ashes, the deputy discovered a burned torso and portions of a human skull.
His brother, John, lived with their mother in Berrien County, Georgia. John and David Woods' aunt lived nearby. Several days before the human remains were found in Florida, on Sept. 28, 2009, Travis Sauls, who lived with the aunt and her son, was sitting outside when John came over and offered to hire Sauls to paint the top of his metal storage container and wash his truck. The next morning, Sauls was seen painting the top of John's storage container. At about 11 a.m., a neighbor heard three or four shots coming from the direction of John's yard.
John Woods told his father he had killed Sauls in self-defense and disposed of the body. Accompanied by his father, John then turned himself in to the sheriff's office, where an attorney had agreed to meet them. On Oct. 3, 5 and 7, 2009, John met with law enforcement officers, where he was represented by the attorney. On Oct. 3, John gave a general statement that he had shot Sauls because he feared for his life. On Oct. 5, John gave more details, stating that while Sauls was washing his truck, Sauls said if anyone ever crossed him, he would kill the person. John said he feared for his life as Sauls began circling him, moving his hands and looking "bug eyed." John went into his house, got his gun and concealing it in a Tom's Potato Chips bag, came back outside and shot Sauls in the back at least twice. John then wrapped the body in a blue plastic "kiddie pool," loaded it onto a trailer and took it to his father's hunting property in Florida. There he burned the body and later scattered the body parts around the property. He returned to his home in Georgia where he showered, burned his clothes and said he cried for "a couple of hours." At the Oct. 7 meeting, investigators asked for, and received, consent to search John's truck, trailer and residence, where they found further evidence.
After John was indicted for murder, his new attorney filed a motion to suppress the evidence gained during the three meetings, contending that his trial attorney had been ineffective for failing to properly investigate Wood's mental condition and allowing him to make statements to investigators. According to the defense, John had suffered from epileptic seizures as a child and taken seizure medication into adulthood. In 2006, he had a right lobe temporal lobectomy in which physicians removed a portion of his brain the size of a golf ball. The trial court denied the motion, finding no ineffective assistance of counsel. In September 2011, a jury convicted him of malice murder, aggravated assault and other charges, and he was sentenced to life plus 10 years in prison. He then appealed to the state Supreme Court.
In today's opinion, the high court finds that the "evidence authorized the jury to find Woods guilty beyond a reasonable doubt of the crime for which he was convicted." And it concludes that John Woods' trial attorney was not ineffective. The attorney was "faced with a client who had decided to turn himself in and had already revealed to a law enforcement officer that he had killed Sauls, claiming self-defense, and that he had attempted to conceal the body," the opinion says. Given the attorney's conduct in light of his own perspective during the interrogations, "we cannot conclude that he rendered ineffective assistance in permitting Woods to cooperate in the interrogations and searches."
However, John Woods also presented evidence that he suffered from a mental disease which could have produced a seizure, causing a temporary delusion that Sauls posed a threat to his life even though in fact he may not have imposed such a threat. During the charge conference prior to jury deliberations, John's trial attorney filed a written request that the jury be instructed on the law regarding a verdict of "not guilty by reason of insanity." The judge agreed to give that instruction. The next day, the trial attorney also requested orally that the jury be instructed on the law regarding self-defense. The trial judge refused, however, stating that the instructions would remain as they had been decided during the previous charge conference.
The judge proceeded to instruct the jury on what must occur for a mental delusion or delusional compulsion to constitute a defense. "This instruction, as far as it goes, is correct," today's opinion says. "But the legal concept of justification is a necessary component of the delusional compulsion defense. In Georgia, a person is not legally insane simply because [he] suffers from schizophrenia or a psychosis….When a delusional compulsion is the basis of an insanity defense, the delusion must be one that, if it had been true, would have justified the defendant's actions."
"Accordingly, the jury could not determine whether Woods was suffering from a delusion that satisfied the legal definition without an understanding of what constituted an act that would have been justified, if the circumstances were as Woods contended he believed them to be, without being instructed as to what conduct would constitute justification."
"Accordingly, Woods must be afforded a new trial."
Attorney for Appellant (Woods): J. Converse Bright
Attorneys for Appellee (State): Cathy Harris Helms, District Attorney, Samuel Olens, Attorney General, Mary Beth Westmoreland, Dep. A.G., Paula Smith, Sr. Asst. A.G., Benjamin Pierman, Asst. A.G.
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