---
title: Reynolds v. State
collection: opinions
id: S26A0946
cite_as: Reynolds v. State, S26A0946 (Ga. Sep. 9, 2026)
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source_url: https://www.gasupreme.us/wp-content/uploads/2026/09/s26a0946.pdf
date: 2026-09-09
status: published
corpus_version: opinions-2026-09-14
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docket: S26A0946
court: Supreme Court of Georgia
case_type: criminal appeal
case_name_full: Montrell Reynolds v. The State
authoring_justice: Ellington
disposition: Affirmed
vote: All the Justices concur
word_count: 2507
date_filed_source: courtlistener
record_source: gasupreme
legal_areas:
  - criminal law
  - evidence law
upstream_id: ga-s26a0946
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---

# Reynolds v. State

Supreme Court of Georgia, docket S26A0946, filed 2026-09-09.

## Opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.

In the Supreme Court of Georgia

No. S26A0946

Montrell Reynolds

v.

The State

On Appeal from the Superior Court of DeKalb County

No. 19CR23243

Decided: September 9, 2026

ELLINGTON, Justice.

Montrell Reynolds appeals his convictions for malice murder and other crimes in connection with the stabbing death of Tolunte Anderson. 1 At trial, Reynolds contended that the jury should have found him not guilty by reason of insanity, but the jury instead found him guilty but mentally ill. On appeal,

1 The crimes occurred on April 26, 2019. On June 25, 2019, a DeKalb County grand jury indicted Reynolds for malice murder (Count 1), felony murder (Count 2), aggravated assault (Count 3), and possession of a knife during the commission of a felony (Count 4). After a trial that began on September 11, 2024, a jury found Reynolds guilty but mentally ill at the time of the crime on all counts. The trial court sentenced Reynolds to life in prison without the possibility of parole for malice murder (Count 1) and five years in prison for possession of a knife during the commission of a felony (Count 4), to run consecutively to Count 1. The felony murder charge (Count 2) was vacated by operation of law, and the aggravated assault charge (Count 3) merged into Count 1. Reynolds timely filed a motion for new trial on October 11, 2024, which was amended by new counsel on October 27, 2025. After a hearing, the trial court denied the motion for new trial on December 1, 2025. Reynolds filed a timely notice of appeal, and this case was docketed in this Court to the April 2026 term.

Reynolds contends that the trial court abused its discretion and harmed his insanity defense when it granted the State’s motion in limine to limit the testimony from the defense’s expert witness. Seeing no reversible error, we affirm.

1. As relevant to this appeal, the evidence presented at trial showed the following. In April 2019, Reynolds was living with Anderson’s family and had been friends with Anderson for over ten years. On the night of April 26, 2019, Reynolds and Anderson were smoking marijuana — which Reynolds later found out was synthetic — and playing video games in Anderson’s bedroom while Anderson’s sister, Teiana Ellison, and her niece and nephews were in her mother’s bedroom watching television. At one point during the night, Ellison was in the kitchen, and Reynolds bumped into her “real hard” and “just walked away” towards Anderson’s room without saying anything. Ellison noticed that Reynolds had a knife in his hand when he was heading back towards Anderson’s room, so she gathered her niece and nephews and returned to her mother’s bedroom. About 15 minutes later, Ellison heard Anderson say from the other room, “After all my momma did for you?”; one of the nephews heard Anderson say, “Chill out, you tripping”; and the niece heard Anderson say, “Stop.” Shortly thereafter, Anderson shouted for Ellison to call the police. Two of the nephews peeked their heads out of the bedroom door and saw Reynolds stabbing Anderson, and they ran to the bathroom where they locked themselves inside. Ellison and the two other children jumped out of the window and ran to a neighbor’s house to call 911.

Law enforcement arrived and encountered Reynolds on the side of the road, covered in blood, attempting to flag down the police. As law enforcement took Reynolds into custody, he complied with the officer’s verbal commands, and he told an officer that he had stabbed his friend and that they had been smoking marijuana. Officers entered the Anderson home and found blood drippings, smears, and spatter on various items and in various rooms throughout the house and found Anderson lying on the floor in a pool of blood, with numerous stab wounds to his upper body. Officers pronounced Anderson dead on the scene, and a medical examiner later declared the manner of death was homicide.

At trial, Reynolds raised an affirmative defense of insanity based on the argument that he was not able to distinguish between right and wrong at the time of the incident. In its presentation of evidence, the defense called its expert witness, Dr. Allison Paganelli, who testified that Reynolds could not distinguish right from wrong when he stabbed Anderson to death. She explained that this was so because, at that time, Reynolds was experiencing symptoms of mental disease and active seizure activity, which were likely made worse by consumption of synthetic marijuana. The jury, however, rejected Reynolds’s insanity defense and found him guilty but mentally ill.

2. Reynolds’s sole enumeration of error relates to the trial court’s ruling on a motion in limine filed by the State to limit Dr. Paganelli’s testimony. In granting the State’s motion, the trial court ruled that Dr. Paganelli would not “be able to definitively state legal conclusions” that Reynolds lacked any “motive” or “plan” for his actions on the night of the crimes or that he made no attempt “to conceal incriminating evidence[.]” Specifically, the court explained:

I’m not going to allow her to testify or state that Mr.

Reynolds had no motive or plan or intent. She can articulate the circumstances, the facts that she found, but as far as how she concluded that he had no motive, how she concluded there was no intent, how she can conclude that there was no plan, I’m not going to let her do that unless, again, she has to come up with a way that she can, without saying the words motive, plan, intent.

On appeal, Reynolds argues that the trial court abused its discretion by precluding the defense’s expert witness from testifying that Reynolds lacked a “motive” or “plan” on the night of the stabbing or that he did not conceal evidence because that testimony would have helped the jury to understand Reynolds’s mental state and whether he could distinguish between right and wrong on that night. Reynolds concedes that, generally, under OCGA § 24-7-704, an expert cannot testify as to conclusions of law or state an opinion as to whether the accused had or lacked the mental state or condition constituting an element of the crime charged. But Reynolds contends that the words “motive” or “plan” or “concealing of evidence” are not inherently legal conclusions nor elements of the crimes charged. Accordingly, he argues, the trial court abused its discretion in granting the State’s motion in limine. But even assuming, without deciding, that the trial court abused its discretion in limiting Dr. Paganelli’s testimony, we conclude that any error was harmless.

“We review the trial court’s grant or denial of a motion in limine for abuse of discretion.” State v. Stephens, 307 Ga. 615, 615 (2020). But even where a trial court abuses its discretion by excluding a witness’s testimony, such error is harmless where “the testimony excluded by the trial court … was duplicative of other portions of [the witness’s] own testimony.” Neuman v. State, 311 Ga. 83, 92 (2021). See also Clark v. State, 321 Ga. 732, 736– 37 (2025) (holding that any error in prohibiting the defendant from reading his prior testimony from the transcript of the pretrial hearing was harmless where his “trial counsel elicited the same testimony from [the defendant] without use of the transcript” because his reading of the transcript “would have been essentially cumulative” (quotation marks omitted)). “In determining whether the error was harmless, we review the record de novo and weigh the evidence as we would expect reasonable jurors to have done so.” Neuman, 311 Ga. at 91 (punctuation omitted). “The test for determining nonconstitutional harmless error is whether it is highly probable that the error did not contribute to the verdict.” Scott v. State, 323 Ga. 312, 316–17 (2026) (punctuation omitted). And whether “it is highly probable that the error did not contribute to the verdict [is] an inquiry that involves consideration of the other evidence heard by the jury.” Smith v. State, 313 Ga. 584, 587 (2022) (punctuation omitted).

Reynolds has failed to demonstrate reversible error because, even assuming, without deciding, that the trial court abused its discretion to some extent by limiting Dr. Paganelli’s testimony, an examination of her testimony reveals that she covered the concepts that Reynolds now complains that she should have been allowed to testify about.

At trial, Dr. Paganelli testified that, during her evaluations of Reynolds, she learned Reynolds’s history of early trauma, mental illness, seizures, epilepsy, paranoia, suicide attempts, and cannabis-use disorder. Dr. Paganelli testified that the use of synthetic marijuana can alter brain function to the point that a person may not be able to tell what is real or not; that it can result in confusion, disassociation, violent behavior, hallucinations, and paranoia; and that, for a person with a preexisting psychotic disorder, use of synthetic marijuana reduces the threshold for psychosis. She also explained that there are multiple phases to a seizure, including the seizure itself (“the ictal phase”) and the period when the person is coming out of the seizure (“the postictal phase”), during which a person can be “combative, not knowing what happened, not knowing where they are,” or experiencing memory loss. She testified that Reynolds described to her multiple times from his past where he ended up in a hospital, confused, following a seizure.

Dr. Paganelli testified that Reynolds reported to her that, on the night of the stabbing, he was hearing a voice telling him to kill himself, that he had memory blackouts during and after the offenses, and that he was confused about why he would stab his best friend. She opined that the amnesia reported by Reynolds was associated with his epilepsy disorder and that, during the stabbing, he was likely experiencing seizure activity and post- seizure symptoms like confusion, headache, and violence. She testified, “Either he was having repeated seizures, or it was the seizure, and then [he was in] the postictal phase, including the violence.”

She opined that this “seizure activity” could have caused his movements that night to appear to witnesses like “organized behavior, like he [knew] what he [was] about to do,” but “that’s not necessarily always the case if someone is having a seizure.” She equated the behavior to sleepwalking. Dr. Paganelli explained that, in contrast to “organized behavior,” “disorganized behavior” is non-intentional, non-purposeful behavior. On cross- examination, Dr. Paganelli was asked whether someone “[e]ngaging in multiple steps that would appear to have a plan would be intentional and organized behavior,” and Dr. Paganelli replied that “[i]t could be unconscious behavior,” because the person could appear to be conscious and know what he is doing but that, if the onlooker attempted to interact with the person, the onlooker would realize the person was actually not behaving consciously.

She testified that the physical evidence that she reviewed also demonstrated either that Reynolds was experiencing “active seizure activity” or that he was in the postictal phase of a seizure at the time of the crimes. Specifically, she reviewed the photographs of the scene showing blood throughout the house, “which suggested that whoever came into contact with the blood was being disorganized … in terms of nothing was cleaned up.” She testified that the photographs showed two knives that were found in plain view and blood on the floors, demonstrating that Reynolds “didn’t try to wash up.” When asked, “And you touched on this earlier, but there didn’t seem to be an obvious reason why this would have happened. Is that your –,” Dr. Paganelli interrupted: “Yes. Based on things I reviewed, and Mr. Reynolds’[s] report.”

She opined that the mental capacity to distinguish right from wrong in a person experiencing these symptoms “would certainly be impaired if the person is not aware of what they’re doing, they’re behaving — they’re unconscious when they’re engaging in behavior, they can’t provide any reason for their behavior.” Dr. Paganelli opined that, on the night of the stabbing, Reynolds was experiencing symptoms of mental disease and active seizure activity, which could have been exacerbated by consumption of synthetic marijuana, and that all of these factors combined and “interacted in a terrible way.” She opined that Reynolds could not distinguish right from wrong “because of the symptoms of those disorders, and the substance use.”

Here, Reynolds was unharmed by the court’s limitation of Dr. Paganelli’s testimony because the expert still testified as to the very concepts that the prohibited words evoke and, thus, “it is highly probable that the error did not contribute to the verdict.” Scott, 323 Ga. at 316–17. Specifically, as to “motive,” on cross- examination, the State asked whether it was the expert’s opinion that “there didn’t seem to be an obvious reason why this would have happened,” and the expert responded, “Yes.”

As to “plan,” the expert was asked whether someone “[e]ngaging in multiple steps that would appear to have a plan” would have constituted organized behavior, and the expert testified that someone experiencing active seizure activity or the postictal phase could act in a way that resembles organized behavior but may actually be “unconscious behavior,” akin to sleepwalking.

As to “attempts to conceal incriminating evidence,” the expert testified that the photographs of the crime scene showed blood throughout the house and suggested that Reynolds’s behavior was “disorganized[,] in terms of nothing was cleaned up,” that two knives were found in plain view, and that he had blood all over his clothing when he went outside and flagged down law enforcement.

All of this testimony — without explicit use of the words prohibited by the granted motion in limine — amounted to an opinion that Reynolds did not have a motive or plan to behave the way he did that night but, rather, his behavior was a product of the combination of his past mental illness, the synthetic marijuana, and potential seizure activity. Reynolds does not point to any testimony that his expert would have testified to if not for the trial court’s ruling that differs substantively from what she testified to at trial. “It is therefore highly probable that the verdicts would have been the same had” the trial court denied the State’s motion in limine and all of Dr. Paganelli’s anticipated testimony been admitted. Neuman, 311 Ga. at 92. Accordingly, we determine that even if the trial court abused its discretion by limiting the witness’s testimony, any error in the trial court’s grant of the motion in limine was harmless because the witness ultimately testified to the substance of what Reynolds now tries to assert the trial court abused its discretion by limiting.

Judgment affirmed. All the Justices concur.

## Summaries written by Georgia Commons

The following was written by claude-sonnet-5 from the opinion above and is not part of the court's opinion. Quote the opinion, not the summary.

The Supreme Court of Georgia upheld a DeKalb County man's murder conviction, ruling that any limits placed on his insanity-defense expert's testimony were harmless because she testified to the same ideas anyway.

### Plain-language summary

Montrell Reynolds was convicted of malice murder after fatally stabbing his longtime friend Tolunte Anderson while the two smoked what turned out to be synthetic marijuana. At trial, Reynolds argued he was insane at the time, unable to tell right from wrong due to mental illness and possible seizure activity, but the jury found him guilty but mentally ill instead of not guilty by reason of insanity.
On appeal, Reynolds argued that the trial judge wrongly limited his defense expert, Dr. Allison Paganelli, from using words like 'motive,' 'plan,' or 'concealing evidence' in her testimony. The Supreme Court of Georgia did not decide whether that limit was improper because it found that, even if it was, the error was harmless: Dr. Paganelli still described the same ideas in other words, so the outcome would not have changed. The court affirmed the conviction.

### Holding, as summarized

The court held that even assuming the trial court abused its discretion by barring the defense expert from using words like 'motive,' 'plan,' or 'concealing evidence,' any error was harmless because the expert's testimony otherwise conveyed the same substantive opinions to the jury without using those specific terms.

### Disposition

Affirmed. All the Justices concur.

### Why it matters

The ruling shows Georgia trial judges have leeway to restrict expert witnesses from using legally loaded words like 'motive' or 'plan,' and that such restrictions are unlikely to overturn a conviction if the expert's substantive opinions still reach the jury through other language.

> The summarized reasoning, checked quotes, suggested questions (1,962 characters) are at https://georgiacommons.org/opinions/S26A0946.md?full=1