Why Georgia’s Street Gang Act May Be Unconstitutional As Applied to Macon’s “Hybrid” Street Gangs

By Dave Oedel
This week, sitting in the gallery during parts of the trial of Andre Maurice Bonner, 32, who was convicted Friday for the murder of 17-year-old Jamonni Bland in the parking deck outside the Zodiac Lounge in Macon near Walnut and Broadway at about 3:30 a.m. on July 5, 2013, I thought about the constitutionality of Georgia’s law on street gangs. Georgia’s Street Gang Terrorism and Prevention Act adds stiff penalties for crimes committed in association with street gangs – sentences of three to fifteen years in addition to the penalties for the predicate crimes committed. Bonner is affiliated with Macon’s Westside Mafia, a so-called hybrid street gang, and Bonner was also convicted of several street-gang enhancements.
The possible unconstitutionality of Georgia’s anti-gang law probably won’t matter to Bonner, though, whose conviction for murder largely moots the issue for him. He’ll be imprisoned for a very long time, so any enhancements to his sentence may well be practically irrelevant. … Continue Reading
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