Ayla King v. State

CourtCourt of Appeals of Georgia
DecidedOctober 28, 2024
DocketA24A1125
StatusPublished

This text of Ayla King v. State (Ayla King 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
Ayla King v. State, (Ga. Ct. App. 2024).

Opinion

SECOND DIVISION MILLER, P. J., MARKLE and LAND, JJ.

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

October 28, 2024

In the Court of Appeals of Georgia A24A1125. KING v. THE STATE.

MILLER, Presiding Judge.

In this criminal case, the trial court closed the courtroom to the public and the

media during jury selection over defendant Ayla King’s objection. The trial court also

denied King’s motion to dismiss the indictment based on an alleged violation of the

right to a speedy trial under OCGA § 17-7-170, and King filed this appeal. We affirm

the denial of the motion to dismiss because the trial was commenced within the

required timeframe. Although we respect the trial court’s rationale for not leaving the

courtroom open, we are required to reverse on this fundamental judicial responsibility

since the court did not leave the courtroom open to the public and the media during

jury selection and did not enter a written order regarding the reasons for closure. On August 29, 2013, an indictment was filed in Fulton County Superior Court

against 61 co-defendants that charged King with one count of violating the Georgia

Racketeer Influenced and Corrupt Organizations Act (OCGA § 16-4-4 (c)). King pled

not guilty and then filed a demand for speedy trial pursuant to OCGA § 17-7-170 on

October 30, 2023, during the September term of court.1 OCGA § 17-7-170 (b) applies

to noncapital cases and pertinently provides that “[i]f the defendant is not tried when

the demand for speedy trial is made or at the next succeeding regular court term

thereafter, provided that at both court terms there were juries impaneled and qualified

to try the defendant, the defendant shall be absolutely discharged and acquitted of the

offense charged in the indictment or accusation.” It is undisputed that there were

juries impaneled and qualified to try King at all relevant times, and therefore the

deadline under OCGA § 17-7-170 (b) was December 31, 2023, the end of the

November term of court.

At the beginning of jury selection on December 11, 2023, prospective jurors

were seated in every gallery row of the courtroom and filled the room to capacity. The

1 The terms of court for the Fulton County Superior Court begin on the first Monday in January, March, May, July, September, and November. OCGA § 15-6-3 (3). 2 trial court stated that in light of the space limitations, it was broadcasting a live audio

and video feed of the proceedings in another part of the courthouse, with the video

focused on the judge, and that members of the public and the media could view this

feed. King requested that the public and the media be allowed in the courtroom,

arguing that a closed courtroom would violate King’s constitutional right to a public

trial. The trial court orally denied King’s request, stating that the court: was

concerned about pre-trial publicity, space in the courtroom, and safety and security

related to jury selection; did not want the names or faces of potential jurors to be

recorded or broadcast to the public; wanted to seat a fair and impartial jury within a

reasonable period of time; and used the least restrictive means to grant access to the

public under the extraordinary circumstances of this case, which involved the largest

number of defendants in the history of Georgia. The trial court did not enter a written

order regarding the courtroom closure. The voir dire phase of jury selection then

proceeded without the public or the media present, although members of the public

were allowed to enter the courtroom once some jurors had been dismissed and space

opened up.

3 On December 13, 2023, the jury was selected and sworn in. The trial court then

stated that opening statements would not occur until January 10, 2024, because the

trial was expected to last three to four weeks, the court would be closed for several

days over the holidays, jurors had holiday and travel plans, and the court wanted to

conduct the trial without interruption.

On January 1, 2024, King filed a motion to dismiss the indictment based on an

alleged violation of the right to a speedy trial under OCGA § 17-7-170, arguing that

King had not been “tried” by the mere selection and swearing-in of the jury and that

the long recess between jury selection and the presentation of evidence undermined

the spirit of the statute. The trial court issued an order denying the motion to dismiss,

concluding that it complied with the statute by impaneling and swearing in the jury,

thereby commencing the trial, within the required timeframe. The court explained

that requiring a trial to be completed rather than commenced before the statutory

deadline would prove unworkable in many circumstances, and here the most prudent

approach was to handle courthouse closures, avoid interruptions, and assuage juror

anxiety based on holiday plans by briefly recessing after the jury was sworn in,

identifying the reason for the delay, and giving the parties the date when the trial

4 would resume.2 King then filed this appeal, challenging both the denial of the motion

to dismiss and the closure of the courtroom during jury selection.

1. King argues that the trial court erred in denying the motion to dismiss for two

reasons. First, swearing in the jury merely sets the stage for trial and does not mean

that a defendant has been “tried” within the plain meaning of OCGA § 17-7-170 (b),

and a case should only be considered to have been tried under the statute when a

verdict has been rendered. Second, even if the statute could be satisfied by swearing

in the jury, federal courts and other state courts have ruled that a significant delay

between the start of trial and the presentation of evidence can violate the spirit of

statutory speedy trial requirements, and acquittal is warranted here due to the

prolonged recess between jury selection and further proceedings. Addressing each

argument in turn, we conclude that the trial court did not err in denying the motion

to dismiss.

(a) We first conclude that a defendant “is . . . tried” under OCGA § 17-7-170

(b) when the trial begins and the jury is selected and sworn in.

2 King filed a motion for reconsideration, which the court denied. 5 “The interpretation of a statute is a question of law, which is reviewed de novo

on appeal.” (Citation omitted.) Jenkins v. State, 284 Ga. 642, 645 (2) (670 SE2d 425)

(2008).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Presley v. Georgia
558 U.S. 209 (Supreme Court, 2010)
Waller v. Georgia
467 U.S. 39 (Supreme Court, 1984)
United States v. Gonzalo Gonzalez
671 F.2d 441 (Eleventh Circuit, 1982)
United States v. Stuart R. Crane
776 F.2d 600 (Sixth Circuit, 1985)
United States v. James Fox
788 F.2d 905 (Second Circuit, 1986)
Jenkins v. State
670 S.E.2d 425 (Supreme Court of Georgia, 2008)
Cobb v. State
621 S.E.2d 548 (Court of Appeals of Georgia, 2005)
Stephens v. State
405 S.E.2d 483 (Supreme Court of Georgia, 1991)
Jones v. State
575 S.E.2d 456 (Supreme Court of Georgia, 2003)
Garvey v. State
335 S.E.2d 640 (Court of Appeals of Georgia, 1985)
Bailey v. State
433 S.E.2d 610 (Court of Appeals of Georgia, 1993)
Southeast Ceramics, Inc. v. Klem
271 S.E.2d 199 (Supreme Court of Georgia, 1980)
Tubbs v. State
583 S.E.2d 853 (Supreme Court of Georgia, 2003)
Hubbard v. State
333 S.E.2d 827 (Supreme Court of Georgia, 1985)
Henry v. James
449 S.E.2d 79 (Supreme Court of Georgia, 1994)
Rockdale Citizen Publishing Co. v. State
463 S.E.2d 864 (Supreme Court of Georgia, 1995)
R. W. Page Corp. v. Lumpkin
292 S.E.2d 815 (Supreme Court of Georgia, 1982)
Goldberg v. State
651 S.E.2d 667 (Supreme Court of Georgia, 2007)
People v. HAJJAJ
241 P.3d 828 (California Supreme Court, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
Ayla King v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ayla-king-v-state-gactapp-2024.