The Georgia Supreme Court issued divergent rulings February 3 in two related appeals arising from the 2018 shooting death of Stanford Duane Jones, with one defendant's conviction standing while another received a new trial based on prosecutorial conflict concerns.
Jeffrey Flakes Jr. and Curtis Williams III were both convicted of malice murder and other crimes in connection with Jones's death on August 10, 2018. The Muscogee County grand jury indicted both men on November 13, 2020, charging them with malice murder, felony murder predicated on aggravated assault, and armed robbery.
The defendants were tried together from October 24 to 28, 2022, with the jury finding both guilty on all charges. However, their post-conviction proceedings and appeals followed markedly different paths, ultimately resulting in contrasting outcomes before the state's highest court.
Flakes received a life sentence with the possibility of parole for malice murder, along with a concurrent life sentence for armed robbery. The felony murder count was vacated by operation of law. He filed a motion for new trial, which he amended twice through different counsel. Following an evidentiary hearing, the trial court denied Flakes's motion for new trial on January 28, 2025.
Flakes subsequently filed a timely notice of appeal to the Georgia Supreme Court. The case was docketed to the August 2025 term and submitted for decision on the briefs. Justice Pinson, writing for the court, affirmed the trial court's denial of Flakes's motion, effectively upholding his conviction and sentence.
Williams faced a different outcome despite identical charges and trial proceedings. He was sentenced to life in prison without the possibility of parole for malice murder, along with a concurrent life sentence for armed robbery. Like Flakes, Williams also filed a motion for new trial, but the trial court granted his motion, prompting the State to file an appeal.
The central issue in Williams's case involves allegations of prosecutorial conflict of interest. According to court records, Williams's motion for new trial was granted on the ground that the prosecutor had previously represented Williams as a public defender in an unrelated matter. This prior attorney-client relationship raised questions about potential conflicts that could have compromised the prosecution's handling of the murder case.
The State now argues before the Georgia Supreme Court that the trial court erred in granting Williams's motion for new trial based on this prosecutorial conflict claim. The State's appeal challenges whether the previous representation created a disqualifying conflict sufficient to warrant overturning Williams's conviction.
Prosecutorial conflicts of interest represent a serious concern in criminal proceedings, as they can undermine the integrity of the adversarial system and potentially violate a defendant's right to effective assistance of counsel. When prosecutors have previously represented defendants in other matters, courts must carefully examine whether confidential information obtained during the prior representation could disadvantage the defendant in the subsequent prosecution.
The Georgia Supreme Court's consideration of this issue could establish important precedent for handling prosecutorial conflicts in the state's criminal justice system. The court's eventual ruling on the State's appeal will determine whether Williams receives a new trial or whether his original conviction stands.
Both cases highlight the complex procedural and ethical issues that can arise in criminal proceedings, even after successful prosecutions result in convictions. The different outcomes for co-defendants tried together demonstrate how individual circumstances and legal challenges can diverge significantly during post-conviction proceedings.
The Supreme Court's opinion, authored by Justice Pinson, is subject to modification under Supreme Court Rule 27 pending any motions for reconsideration or editorial revisions. The final version will be published in the Advance Sheets for the Georgia Reports and will replace any prior versions on the court's website.
For Flakes, the Supreme Court's decision represents the end of his direct appeal process, barring any extraordinary post-conviction remedies. His life sentence with the possibility of parole remains in effect.
Williams's case remains pending as the Supreme Court considers the State's appeal. If the high court reverses the trial court's order granting a new trial, Williams would face his original sentence of life without parole. However, if the Supreme Court affirms the grant of a new trial, Williams could face retrial on the murder charges, potentially with different prosecutorial representation to address the conflict concerns.
The cases underscore the ongoing complexity of capital and serious felony prosecutions in Georgia, where procedural safeguards and ethical considerations continue to shape outcomes long after initial verdicts are reached.