The Supreme Court of Georgia affirmed Zajaliq Riley's 2023 felony murder conviction Monday, rejecting his arguments that prosecutors committed constitutional violations during his trial for the shooting death of Devion Miley.
Riley was convicted in August 2023 of felony murder and possession of a firearm during the commission of a felony in connection with Miley's death on May 8, 2021, in Muscogee County. The conviction stemmed from allegations that Riley and co-defendant Detric Bush killed Miley during an attempted marijuana sale.
In his appeal, Riley argued that the State violated his due process rights under Brady v. Maryland by failing to disclose an agreement to give Bush leniency in an unrelated Troup County case in exchange for his testimony against Riley. Riley also claimed his trial counsel provided ineffective assistance by failing to cross-examine Bush about the Troup County matter.
The Brady doctrine, established in the 1963 Supreme Court case Brady v. Maryland, requires prosecutors to disclose material evidence favorable to the defense, including evidence that could impeach prosecution witnesses. Violations of this rule can result in overturned convictions when the undisclosed evidence could have affected the trial's outcome.
Presiding Justice Warren wrote the court's opinion rejecting Riley's claims. The court found that evidence presented at the motion for new trial hearing demonstrated there was no agreement regarding Bush's Troup County case before Riley's trial concluded. This factual finding undermined Riley's Brady violation claim, as there was no undisclosed agreement to conceal from the defense.
At Riley's trial, Bush testified as a key prosecution witness. According to the court's opinion, Bush knew both Riley and Miley from school and provided testimony linking Riley to the fatal shooting. The prosecution's case relied significantly on Bush's testimony to establish Riley's involvement in the crime.
Riley's defense team argued that any agreement or understanding between prosecutors and Bush regarding his separate Troup County case should have been disclosed to allow for effective cross-examination. Defense attorneys could have used such information to challenge Bush's credibility and suggest his testimony was motivated by hopes of lenient treatment rather than truthfulness.
The court also rejected Riley's ineffective assistance of counsel claim. Under the legal standard established in Strickland v. Washington, defendants must prove both that their counsel's performance was deficient and that the deficiency prejudiced their defense. The Georgia Supreme Court found Riley failed to demonstrate the required prejudice from his counsel's allegedly inadequate cross-examination of Bush.
The case highlights the ongoing tensions in criminal law between prosecutorial discretion in witness cooperation and defendants' rights to know about potential bias affecting witness testimony. Brady violations remain a significant issue in criminal appeals, with courts regularly reviewing whether prosecutors properly disclosed agreements or understandings with cooperating witnesses.
Riley's conviction represents another chapter in Georgia's handling of felony murder cases, where defendants can be convicted of murder even if they did not directly cause the death, provided the killing occurred during the commission of certain felonies. The firearm possession charge carried additional penalties reflecting Georgia's tough stance on gun crimes.
The Supreme Court of Georgia's decision in Riley v. The State was decided February 3, 2026, and designated as case number S26A0073. The court's opinion noted that it remains subject to potential modification through reconsideration motions and editorial revisions before final publication in the Georgia Reports.
The affirmance means Riley's convictions stand, and he will continue serving his sentence for the felony murder of Miley and the firearm possession charge. The ruling reinforces prosecutorial authority in managing witness cooperation while establishing that defendants must prove actual agreements existed and caused prejudice to succeed on Brady claims.
For prosecutors, the decision provides guidance on the timing and nature of disclosure obligations regarding witness cooperation. The court's emphasis on when agreements were reached suggests that informal understandings or post-trial benefits may not trigger Brady disclosure requirements if not formalized before testimony.
The case also demonstrates the high bar defendants face in proving ineffective assistance of counsel. Even when attorneys potentially miss cross-examination opportunities regarding witness bias, courts require clear evidence that different representation would have changed the trial's outcome.
Riley's case joins the body of Georgia precedent addressing prosecutorial misconduct claims and the boundaries of effective legal representation in serious felony cases. The decision reflects the court's careful balancing of defendant rights against prosecutorial needs in complex criminal cases involving cooperating witnesses.