Adam Mitchell v. State

CourtCourt of Appeals of Georgia
DecidedFebruary 22, 2023
DocketA22A1521
StatusPublished

This text of Adam Mitchell v. State (Adam Mitchell v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adam Mitchell v. State, (Ga. Ct. App. 2023).

Opinion

THIRD DIVISION DOYLE, P. J., BROWN, J., and SENIOR APPELLATE JUDGE PHIPPS

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

February 22, 2023

In the Court of Appeals of Georgia A22A1521. MITCHELL v. THE STATE.

DOYLE, Presiding Judge.

A jury convicted Adam Mitchell of trafficking, manufacture of

methamphetamine, possession with the intent to distribute, possession of

methamphetamine, possession of altered ephedrine or pseudoephedrine, and

conspiracy to manufacture methamphetamine.1 The trial court denied his amended

motion for new trial, and he now appeals, arguing that the trial court’s denial was in

error because (1) a witness provided false testimony, (2) certain counts on which

Mitchell was sentenced were subject to merger, and (3) Mitchell received ineffective

1 See OCGA §§ 16-13-31 (f); 16-13 -30 (a), (b); 16-13-30.3 (d) (2007); 16-13- 33. Although Mitchell was also indicted on multiple charges of possession of a firearm by a convicted felon, the trial court entered a nolle prosequi regarding these charges. assistance of counsel. For the reasons set forth infra, we affirm in part and vacate in

part, and remand for resentencing.

Construed in favor of the verdict,2 the record shows that in 2008, the Lookout

Mountain drug task force investigated people buying large amounts of medications

containing pseudoephedrine that were then sold to manufacture methamphetamine.

The drug task force questioned Brian Jumper, who was on parole at the time,

regarding his purchases of such medications. Jumper initially told police that he

bought the pills because he had a cold, but when officers indicated that they did not

believe his story, Jumper stated that he bought them for Mitchell who was using the

pills to manufacture methamphetamine. At trial, Jumper testified that he had

purchased pills for Mitchell on approximately five or six occasions, and Mitchell paid

him with half a gram of methamphetamine each time. Jumper also testified that he

saw Mitchell “cook” methamphetamine on one occasion.

Police arrested Jumper approximately a week after his interview. He entered

a guilty plea and received a sentence of fifteen years with eight years to be served in

confinement. Jumper’s sentencing form stated that he was to “testify truthfully at

2 See Toney v. State, 304 Ga. App. 25 (695 SE2d 355) (2010).

2 [Mitchell’s] trial[.]” At trial, however, when asked if he made “any deals to have to

testify or anything that [he was] aware of[,]” Jumper answered that he had not.

The drug task force obtained a warrant to search Mitchell’s property and

discovered several items often used in the clandestine manufacturing of

methamphetamine. Officers also discovered coffee filters, which tested positive for

methamphetamine, and a coffee grinder whose lid tested positive for ephedrine or

pseudoephedrine. The arresting officer testified at trial that Mitchell informed the

officer that he had “cooked” and used methamphetamine, and that Mitchell had stated

that he had secured medicine containing pseudoephedrine from Jumper and others by

providing them cash or methamphetamine in exchange for the pills. The officer also

testified that Mitchell had stated that he learned the drug task force was “visiting”

people, and that he subsequently decided to clean up the items he used to manufacture

methamphetamine, which according to the officer, explained why some items they

discovered appeared to have been hidden.

3 A jury found Mitchell guilty on all counts, and he filed a motion for new trial.3

Following a hearing, the trial court denied Mitchell’s motion for a new trial, and he

filed this appeal.

When reviewing a claim that the State failed to correct false testimony, we

accept the court’s factual findings unless clearly erroneous, while we review the

court’s application of the law to the facts de novo.4 Additionally, “[t]he question of

whether offenses merge is a legal question that we review de novo.”5 Finally, “[w]hen

reviewing a trial court’s ruling on the effectiveness of trial counsel, we accept the trial

court’s factual findings and credibility determinations unless clearly erroneous, but

3 We note that Mitchell’s case was tried and his original motion for new trial was filed in 2009, but his motion for new trial hearing was not held and an order on his motion was not entered until 2021. We do not condone this delay. As the Supreme Court of Georgia has stated, “[t]hese delays put at risk the rights of defendants and crime victims and the validity of convictions obtained after a full trial. . . . [I]t is the duty of all those involved in the criminal justice system. . . to ensure that the appropriate post-conviction motions are filed, litigated, and decided without unnecessary delay.” Shank v. State, 290 Ga. 844, 849 (5) (c) (725 SE2d 246) (2012). (punctuation omitted). 4 See Hood v. State, 311 Ga. 855, 863 (1) (860 SE2d 432) (2021) (citing the standard of review for similar Brady claim); Love v. State, 349 Ga. 741, 746 (3) (824 SE2d 745) (2019). 5 Morris v. State, 340 Ga. App. 295, 312 (7) (797 SE2d 207) (2017).

4 we independently apply the legal principles to the facts.”6 With these guiding

principles in mind, we turn now to Mitchell’s claims of error.

1. Mitchell argues that the trial court erred in denying his motion for new trial

because the State’s witness provided false testimony at trial. Specifically, Mitchell

asserts that he was entitled to a new trial because Jumper denied having an agreement

to testify at Mitchell’s trial, the State knowingly failed to correct this false testimony,

and the false statement was material to the trial’s outcome.

In general, a Giglio[7] claim alleges that a prosecutor knowingly presented false testimony against the defendant. To establish a Giglio violation, it must be shown that: (1) the testimony given was false; (2) the prosecutor knew the testimony was false; and (3) the statement was material.8

Here, the State does not dispute that Jumper offered false testimony, i.e., falsely

stating that he did not have an agreement with the State to testify at Mitchell’s trial.

6 (Citation and punctuation omitted.) Evelyn v. State, 347 Ga. App. 368, 371 (819 SE2d 657) (2018). 7 Giglio v. United States, 405 U. S. 150, 153-154 (92 SCt 763, 31 LE2d 104) (1972). 8 (Citations and punctuation omitted.) Love, 349 Ga. App. at 746 (3).

5 However, “[t]he burden is on the defendant to prove each of these elements[,]”9 and

reversal of the trial court is required “only if there is a reasonable probability that, had

the evidence been disclosed to the defense, the result of the proceeding would have

been different.”10

When considering whether false testimony offered at trial was material, this

Court has held that “the false evidence is material if there is any reasonable likelihood

that the false testimony could have affected the judgment of the jury.”11 Here, a search

of Mitchell’s property uncovered several items and substances associated with the

clandestine manufacture of methamphetamine. Additionally, the arresting officer

testified that Mitchell had admitted he both used and manufactured

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Giglio v. United States
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Alford v. State
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Johnson v. State
630 S.E.2d 778 (Court of Appeals of Georgia, 2006)
Toney v. State
695 S.E.2d 355 (Court of Appeals of Georgia, 2010)
Carolina v. State
690 S.E.2d 435 (Court of Appeals of Georgia, 2010)
Land v. State
578 S.E.2d 551 (Court of Appeals of Georgia, 2003)
Sharpe v. State
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Arnold v. State
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Adam Mitchell v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/adam-mitchell-v-state-gactapp-2023.